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PRIVACY POLICY
PRIVACY PRINCIPLES
Your privacy is important to us. This Online Privacy Policy explains what and
how we collect, share, use, and protect your personal information when you visit
or use this and other online services offered by the JPMorgan Chase & Co. family
of companies (“J.P. Morgan”) that link to or reference this Policy
(collectively, our “online services”). Contact details are provided below. Other
privacy principles or policies could apply depending on how you interact with
us, the financial products or services you may ultimately obtain from us, or the
jurisdiction in which we are doing business with you. For example, if you are a
California resident, you may have rights under the California Consumer Privacy
Act as described in our CCPA disclosure. You can access many of these policies
using the links at the bottom of this page.
* WE WORK HARD TO PROTECT YOUR INFORMATION.
We take our responsibility to protect the privacy and confidentiality of your
information, including personal information, very seriously. We maintain
physical, electronic and procedural safeguards that comply with applicable
legal standards to secure such information from unauthorized access and use,
accidental or unlawful alteration and destruction, and other unlawful or
unauthorized forms of Processing. We hold our employees accountable for
complying with relevant policies, procedures, rules and regulations
concerning the privacy and confidentiality of information.
* WE WANT YOU TO UNDERSTAND THE TYPE OF INFORMATION WE COLLECT AND HOW WE USE
IT.
* The types of personal information we collect from you when you visit or use
our online services include your name, email address, mailing address,
telephone number(s), account numbers, limited location information (for
example, a zip code to help you find a J.P. Morgan office near you), user
name and password. We may also collect payment card information, Social
Security numbers, driver’s license numbers (or comparable), gender, race,
nationality, and biometric identifiers when you provide it directly to us
while using our online services and where we believe it is reasonably
required for ordinary business purposes. In some instances, we create
personal information about you, such as records of your interactions with
us, and details of your accounts. We do not seek to collect or process
sensitive personal information unless it is required or permitted by law;
necessary for the detection or prevention of crime; necessary to establish,
exercise or defend legal rights; or we have your prior explicit consent.
* In addition to the personal information described above, we collect certain
information about your use of our online services. For example, we capture
the IP address of the device you use to connect to the online service, the
type of operating system and browser you use, and information about the
site you came from, the parts of our online service you access, and the
site you visit next. As explained in more detail in our Cookies Policy, we
and our third-party partners use cookies (as well as web beacons or other
technologies) to collect and store this and other information about your
visit to, or use of, our online services. We may later associate the usage
and other information we collect online with personal information about
you, as permitted or required by law.
Link to Cookies policy
* We sometimes collect information about you from additional online and offline
sources including social media (to the extent you choose to make your
personal information public) and commercially available third-party sources,
such as credit reporting agencies. We may combine this information with the
personal and other information we have collected about you under this Online
Privacy Policy.
* Where we are required to establish a legal basis to process your personal
information as described in this Online Privacy Policy, we will do so on
the basis that we have obtained your prior express consent to the
processing; we have a legitimate business interest in the processing that
is not overridden by your interests, fundamental rights, or freedoms; or
the processing is needed to comply with applicable law, to perform under
your contract(s) with us, or to protect the vital interests of any
individual.
* We use and otherwise process the information we collect from you to help us
deliver our online services; to administer, evaluate and improve our
business (including developing new products and services, improving
existing products and services, performing data analytics and other
research tasks, communicating with you via any means, and performing
accounting, auditing and other internal functions); manage our risks; to
market our services and products; and to comply with and enforce applicable
laws and regulations, relevant industry standards, contractual obligations
and our policies. We also use data that we collect on an aggregate or
anonymous basis (such that it does not identify any individuals or clients)
for various business purposes, where permissible under applicable laws and
regulations.
* WE AIM TO COLLECT ONLY WHAT WE NEED, KEEP IT UP-TO-DATE AND REMOVE IT WHEN WE
NO LONGER NEED IT.
* We take reasonable steps to ensure that the personal information we process
is limited to what we require in connection with the purposes set out in
this Policy; it is accurate and, where necessary, kept up to date; and it
is erased or rectified without delay if it is inaccurate. From time to time
we may ask you to confirm the accuracy of your personal information.
* For some of our online services, you can review or update certain account
information by logging in and accessing the “Client Center” or a similar
user profile section. If you cannot change the incorrect information
online, or you prefer to request changes offline, please contact your
J.P. Morgan representative using the contact information listed on your
account statements, records, or other account materials.
* We will retain copies in a form that permits identification for as long as
we deem necessary in connection with the purposes set out in this Policy,
unless applicable law requires a longer retention period. In particular, we
will retain personal information for as long as it is needed to establish,
exercise or defend any legal rights.
* WE RESPECT AND PROTECT YOUR PRIVACY EVEN WHEN YOU’RE ON THE GO.
* For your convenience, J.P. Morgan offers you the ability to access some of
our products and services through mobile applications and mobile-optimized
websites. When you interact with us through your mobile device, we collect
information such as unique device identifiers, your screen resolution and
other device settings, information about your location, and analytical
information about how you use your mobile device. We typically ask your
permission before collecting certain information such as precise
geolocation information.
* WE SHARE PERSONAL INFORMATION WITH AFFILIATES AND WITH OTHERS WHEN WE BELIEVE
IT WILL ENHANCE THE SERVICES AND PRODUCTS WE CAN PROVIDE TO YOU OR FOR LEGAL
AND ROUTINE BUSINESS REASONS.
* We share personal information among our affiliates and business units when
we believe it will enhance the services we can provide, but only in
circumstances where such sharing conforms to law, any applicable
confidentiality agreements, and our policies and practices. Additionally,
we reserve the right to share your personal information in connection with
a corporate change including a merger, acquisition or sale of all or any
relevant portion of our business or assets.
* We disclose information we have about you as required or permitted by law.
For example, we share information with regulatory authorities and law
enforcement officials when we believe in good faith that such disclosure is
necessary to comply with legal requirements.
* We share information with third parties where appropriate to protect
against fraud or verify or enforce our terms of use, our other rights, or
other applicable policies.
* From time to time, we enter into agreements with other companies to provide
services to us, or to make services and products available to you. If these
companies receive your personal information, they are required to safeguard
it and only use it for those purposes we specify.
* J.P. Morgan believes that keeping your information secure and private is
important, particularly when using third-party websites and applications
that can help you invest or manage your finances. In partnering with
Intuit, which provides the aggregation service Mint, J.P. Morgan has taken
measures to keep your logon information secure and private. When you are
prompted to provide your J.P. Morgan user ID and password to Mint, you will
be entering your information directly into a J.P. Morgan protected site.
Mint will not see or be able to store your user ID and password, and will
only require a single logon for all of your devices and browsers to work.
* We can share your personal information with any person or entity if we have
your consent to do so.
* WE TRANSMIT, TRANSFER OR PROCESS INFORMATION TO, OR THROUGH, OTHER COUNTRIES
IN THE WORLD, AS WE DEEM NECESSARY, APPROPRIATE OR CONSISTENT WITH LEGAL OR
REGULATORY OBLIGATIONS.
* As a global company, we strive to provide you with access to the highest
quality financial products and services wherever you are. To do this, we
sometimes share your personal information among members of the JPMorgan
Chase & Co. family of companies or service providers and other third
parties that are located outside your home country. These countries may
have different laws and data protection compliance requirements, with some
providing more protection than others. J.P. Morgan will take appropriate
steps to ensure your personal information is handled as described in this
Online Privacy Policy.
* Where required, we comply with applicable legal frameworks relating to the
transfer of personal information. For example, under the European rules
designed to adequately protect personal information transferred outside the
European Economic Area we transfer personal information on the basis of
determinations by the European Commission that certain countries adequately
protect personal information, our Binding Corporate Rules, approved Model
Contractual Clauses, and other valid transfer mechanisms.
* WE RESPECT YOUR RIGHTS CONCERNING THE PROCESSING OF PERSONAL INFORMATION AND
PROVIDE YOU WITH RELEVANT AND APPROPRIATE CHOICES.
DEPENDING ON HOW AND WHERE YOU INTERACT WITH US, YOU MAY HAVE A RIGHT TO ONE
OR MORE OF THE FOLLOWING WITH RESPECT TO YOUR PERSONAL INFORMATION WE PROCESS
OR CONTROL:
* request access to, or copies of, your personal information, together with
details about how we process it;
* request rectification of any inaccuracies;
* request erasure or restriction of Processing;
* object to processing by us or on our behalf;
* have personal information transferred to another party;
* withdraw consent to processing; and
* lodge complaints with a data protection authority regarding any processing
by us or on our behalf.
* To exercise one or more of these rights or to ask a question about them,
please use the contact details provided below.
* In addition to the rights you have under applicable data protection laws, we
may give you choices regarding the sharing of personal information with
affiliates and third parties based on your relationship(s) with us as a
financial institution. Choices you have about the sharing of your personal
information will be described in the privacy policies or notices you receive
from us, such as those provided in connection with particular financial
products or services you obtain from us.
* We respect your decisions about the collection of personal information
related to your online activities over time and across different websites for
advertising purposes.
* J.P. Morgan does not allow unaffiliated third parties to collect personal
information about your online activities when you visit our online services.
Nor do we use personal information collected across non-affiliated websites
for the purpose of serving you advertising related to your browsing behavior.
If we engage in this practice in the future, we will provide appropriate
notice and choice so that you can opt-out of the practice.
* We tell you when our privacy policies and practices change.
* We want to hear from you if you have questions.
* If you have any comments, questions or concerns about any of the
information in this Online Privacy Policy, or any other issues relating to
the processing of your personal information by J.P. Morgan under this
Policy, please contact your regular J.P. Morgan client service contact, or:
Global Privacy Office, JPMorgan Chase & Co.
245 Park Avenue, New York, NY 10017
Email: jpmc.cpo@jpmchase.com
RELATED LINKS
* J.P. Morgan Wealth Management U.S. Privacy Notice (clients served by Wealth
Partners or Wealth Advisors)
* JPMorgan Chase Bank N.A. – Philippine Global Service Centre Privacy Notice
* J.P. Morgan Securities Philippines, Inc. - Supplement to Privacy Policy
* JPMorgan Chase Bank, N.A. Manila Branch - Supplement to Privacy Policy
* Latin America Private Bank Privacy Notice
* Política de Privacidade para área de Private Bank na América Latina
* Aviso de Privacidad de la Banca Privada de América Latina
* J.P. Morgan Brazil General Data Protection Law Privacy Policy for Corporate &
Investment Bank, Commercial Banking and Asset Management
* J.P. Morgan Brazil General Data Protection Law Privacy Notice for Private
Bank
* California Consumer Privacy Act
* J.P. Morgan Private Bank Privacy Notice for U.S. Clients
* Cayman Islands Data Protection Law Privacy Notice for Asset & Wealth
Management Clients
* J.P. Morgan Privacy Statement for Merchant Services
* J.P. Morgan EMEA Privacy Policy for Asset Management
* J.P. Morgan EMEA Privacy Notice for Private Bank
* J.P. Morgan APAC Privacy Notice for Private Bank
* J.P. Morgan APAC Privacy Notice for Private Bank (Bahasa Indonesia)
* J.P. Morgan EMEA Privacy Policy for Corporate & Investment Bank and
Commercial Bank (includes EU, UK, MENA, South Africa, Cayman Islands, and
other jurisdictions)
* JPMorgan Binding Corporate Rules for Controllers (UK)
* JPMorgan Binding Corporate Rules for Controllers (EU)
* J.P. Morgan Privacy Policy for use in its New Zealand Operations
* J.P. Morgan Privacy Policy for use in its Australian Operations
* J.P. Morgan Canada Privacy Notice
* Privacy Policy of JPMorgan Chase Bank N.A., Mumbai Branch, J.P. Morgan India
Private Limited, J.P. Morgan Securities India Private Limited and J.P. Morgan
Advisors India Private Limited
* J.P. Morgan Asset Management Hong Kong Personal Data Privacy Statement
* J.P. Morgan Privacy Policy for Singapore
* JPMorgan South Africa (JPMSA) Privacy Notice Addendum
* JPMorgan South Africa PAIA POPIA Manual
* J.P. Morgan Privacy Policy for Thailand
LOCAL COUNTRY PRIVACY INFORMATION
BRAZIL
If you would like to contact the J.P. Morgan Data Protection Officer for Brazil,
please send an email to or via post to / Caso queira contatar a Encarregada de
Proteção de Dados do J.P. Morgan Brasil, envie um email ou correspondência para:
Solange Mendonça
Email: Brasil.DPO@jpmchase.com
Address / Endereço: Avenida Brigadeiro Faria Lima 3729, 10 Andar - Sao Paulo/SP,
04538--905, Brasil
Related Links
* J.P. Morgan Brazil General Data Protection Law Privacy Notice for Private
Bank / Política de Privacidade do J.P. Morgan para o Private Bank - Lei Geral
de Proteção de Dados
* J.P.Morgan Brazil General Data Protection Law Privacy Policy for Corporate &
Investment Bank, Commercial Banking and Asset Management / Política de
Privacidade do J.P. Morgan para o Corporate & Investment Bank, Commercial
Banking e Asset Management - Lei Geral de Proteção de Dados
PRIVACY POLICY – J P MORGAN SERVICES INDIA PRIVATE LIMITED
1. INTRODUCTION
This Policy applies to J.P. Morgan Services India Private Limited (referred to
as “JPMSIPL”).
As per the requirements of the Information Technology (Reasonable Security
Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011
("RSP Rules") this Policy outlines the manner in which the Personal Information
or Sensitive Personal Information will be handled or dealt with by JPMorgan
India.
JPMSIPL recognizes the importance of Personal Information including Sensitive
Personal Data or Information (defined in Clause 2 below), provided to it by
natural persons (Information Providers defined in Clause 2 below), under lawful
contract and the trust they place with respect to maintaining the security of
this information. With respect to Personal Information including Sensitive
Personal Data or Information (SPDI), JPMSIPL will take reasonable steps to keep
such information confidential and may share it with affiliates and third parties
on a need-to-know basis under appropriate arrangements.
You agree and confirm that JPMSIPL may collect, store, process, disclose and
transfer the Personal Information including SPDI collected about you to any of
its affiliates, agents or third party service providers in connection with the
products or services you have sought from, or your employment with JPMSIPL or to
provide better services to you or to ensure compliance with a legal or
contractual obligation of JPMSIPL. The purpose for which JPMSIPL would collect
and use your SPDI includes instances set out in Clause 3.2 below. The types of
third parties (whether in India or overseas) that your SPDI could be disclosed
to, includes the types of third parties mentioned at Clause 5 below. You confirm
that the SPDI so far collected, stored, processed, disclosed and transferred by
JPMSIPL in the course of your employment for the above purposes shall continue
to be used by JPMSIPL strictly in accordance with the applicable laws.
2. DEFINITIONS
2.1 Personal Information (the “PI”) - for the purposes of this Policy, refers to
any information that relates to a natural person which either directly or
indirectly, in combination with other information available or likely to be
available with a body corporate, is capable of identifying such person such as
name or address and to be read with the relevant internal policies including the
Global/Regional Privacy policies.
2.2 Sensitive Personal data or information of a person (the “SPDI”) - for the
purposes of this Policy, shall be the same as defined in the Information
Technology (Reasonable Security Practices and Procedures and Sensitive Personal
Data or Information) Rules, 2011 (the “SPDI Rules”), as amended from time to
time. i.e.
(i) Password;
(ii) Financial information such as Bank account or credit card or debit card or
other payment instrument details;
(iii) Physical, physiological and mental health condition;
(iv) Sexual orientation;
(v) Medical records and history;
(vi) Biometric information;
(vii) Any detail relating to the above clauses as provided to us for providing
services; and
(viii) Any of the information received under any of the above clauses by us for
processing, storing or processing under lawful contract or otherwise.
Provided that any information that is freely available or accessible in public
domain or furnished under the Right to Information Act, 2005 or any other law
for the time being in force shall not be regarded as Sensitive Personal
Information for the purposes of this Policy.
2.3 Information Provider - for the purpose of this Policy, refers to a natural
person or individual who provides PI or SPDI to JPMSIPL. In this Policy, the
Information Providers are referred to as "You".
3. PURPOSE OF COLLECTION AND USE OF SPDI
3.1. JPMSIPL will ordinarily collect Personal Information including SPDI that it
believes is necessary for any purpose connected with a function or activity
necessary to deliver, promote or market services or to carry out primary
business functions and/or activities, comply with applicable regulations or in
the capacity as an employer or a counterparty to agreements with individuals.
Ordinarily, JPMSIPL will only collect such SPDI about you when you provide it or
you have consented to provide the information or where it is required by law.
JPMSIPL will collect such information from you in the course of your employment
and use the information during the tenure of your employment. Any such
information collected will be kept confidential.
3.2. In general, we would be collecting/handling/ storing/ using or transferring
your SPDI for the following, including but not limited to:
3.2.1 complying with legislative and regulatory requirements
3.2.2 providing a service to you
3.2.3 maintaining an employment relationship with you:
3.2.4 performing administrative functions; and
3.3 The SPDI collected from you may be collected and/or retained either directly
by JPMSIPL or through or with an affiliate or third party.
JPMSIPL, its affiliates and third parties it shares SPDI with, will retain the
SPDI for a reasonable period for the purposes for which such information has
been collected and as may be lawfully used or is otherwise required under any
law for the time being in force.
The SPDI collected shall be used for the purpose for which it has been
collected.
You have the option not to provide JPMSIPL with the SPDI sought to be collected.
You also have the option to withdraw the consent given earlier, provided it is
sent to us in writing. In the event SPDI which JPMSIPL deems necessary for
providing you with any service is not provided or if consent is withdrawn
subsequently, JPMSIPL reserves the right not to provide you with such services/
benefits/ amenities and take any other action in this regard on just and
reasonable grounds.
4. PERSONAL INFORMATION INCLUDING SPDI ABOUT THIRD PARTIES
While providing Personal Information including SPDI of another natural person
(particularly of spouse, children or parents) to JPMSIPL, please ensure that you
have the necessary concurrence of that natural person.
5. DISCLOSURE OF SENSITIVE PERSONAL INFORMATION
5.1 In general, JPMSIPL will not use or disclose SPDI collected about you to a
third party otherwise than for the purposes set out in this Policy, unless the
disclosure is necessary for compliance of a legal obligation or where it is
agreed to in the contract with you or as consented by you and supported by a
valid non-disclosure contract or provisions in the legal contract.
5.2 Provided that such information shall be shared without your consent, with
government agencies mandated under law to obtain information including SPDI for
the purpose of verification of identity or for prevention, detection,
investigation including cyber incidents, prosecution and punishment of offences
or any law enforcing authorities.
5.3 Notwithstanding anything contained in the preceding paragraphs of this
section, any SPDI shall be disclosed to any third party by an order under a law
for the time being in force.
5.4 You authorize JPMSIPL to disclose necessary SPDI to certain employees,
consultants, employees or consultants, of JPMSIPL affiliates, agents or third
party service providers within India or outside India who provide services to
JPMSIPL in connection with the services you have sought from, or, your
employment with, JPMSIPL, on a need-to-know basis. These parties shall use your
SPDI only for the specific purpose for which JPMSIPL supplies the SPDI to them
and from disclosing it further.
5.5 Subject to what is permitted by law, the types of third parties (whether in
India or overseas) your SPDI could be disclosed to may include:
5.5.1 agents, contractors, service providers, insurers and external advisers
engaged by JPMSIPL from time to time to carry out, provide services or advise on
the functions and activities;
5.5.2 other related bodies corporate /affiliates of JPMSIPL;
5.5.3 any person or organization who introduces you to JPMSIPL;
5.5.4 regulatory bodies, government agencies, law enforcement bodies and courts;
5.5.5 any person or organization who JPMSIPL deems necessary for carrying out
the instructions you give to JPMSIPL; and
5.5.6 any prospective transferee in a scheme of arrangement, amalgamation,
merger or sale of shares or sale of business relating to the whole or part of
JPMSIPL.
6. TRANSFER OF SENSITIVE PERSONAL INFORMATION
JPMSIPL may transfer your SPDI to any person or entity, whether in India or
located in any other country, that ensures a similar level of data protection as
JPMSIPL employs when it is necessary for the performance of a lawful contract
with you or where you have consented to such transfer.
7. ACCESS TO YOUR SENSITIVE PERSONAL INFORMATION
You may review and correct or revise the Personal Information including SPDI you
have provided to us for the purpose of ensuring the said information is
accurate. JPMSIPL shall not be responsible for the authenticity of the
information you have supplied to it or to any person acting on its behalf.
JPMorgan India may not be able to provide access to information which is not
directly provided by you. JPMorgan India may charge you a fee for accessing your
SPI.
8. INFORMATION SECURITY STANDARD FOR SPDI AT JPMSIPL
JPMSIPL operates in an environment that is similar to the requirements of
ISO/IEC 27001 Security Standards for ensuring that the SPDI it holds is
protected from misuse, loss and unauthorized access, modification or disclosure.
9. GRIEVANCE HANDLING
You may contact the Grievance Redressal Officer (GRO), who is the designated
grievance officer, for any grievances with respect to processing your Sensitive
Personal Information. JPMSIPL will make every effort to resolve your grievance
expeditiously.
Name of GRO: Kesavan Narayanan
Email: kesavan.narayanan@jpmorgan.com
10. CHANGES TO THIS PRIVACY POLICY
Please note that this Privacy Policy may change from time to time. Your
continued engagement with us will indicate your acceptance of such changes.
Employees may at any time access a current version of the Privacy Policy from
the Intranet.
JPMSIPL encourages you to review the Privacy Policy periodically for updations,
if any.
11. NEED MORE INFORMATION?
If you have a query concerning how your SPDI is collected and used or in
relation to JPMorgan's Privacy Policy or there are any discrepancies in regard
to your SPDI and needs an updation, please contact Access HR.
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