1. Background

1.1      This Privacy Notice explains how Jupiter Fund Management Plc, its subsidiaries and its affiliates, and/or any funds operated or managed by them (referred to collectively as “Jupiter” “we”, “us” or “our”), each a controller, collect and process certain Personal Data. Jupiter is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.

1.2       At Jupiter we respect the privacy of individuals and we are committed to keeping all your Personal Data secure. This Privacy Notice (“notice”) applies to individuals outside our organisation with whom we interact, including but not limited to visitors to our website; clients and their personnel; vendors and service providers; visitors to our offices; and registrants for Jupiter events (together, “you”).

1.3      We use the following definitions in this Privacy Notice:

“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Jupiter (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Jupiter or any other person in respect of an individual.

2. The products and services we provide

2.1       This Privacy Notice concerns the following categories of information that we collect about you when providing the following products and services (together, the “services”):

(A) Information we receive through our websites (“Jupiter Websites“);
(B) Information we receive through our products (“Jupiter Products“);
(C) Information we receive through our support, mobile security solution or cloud-based services (“Jupiter Services“).

3. The types of personal data we collect

3.1      Many of the services offered by Jupiter require us to obtain Personal Data about you in order to perform the services we have been engaged to provide. In relation to each of the services described at section 2.1 above, we will collect and process the following Personal Data about you:

Information that you provide to Jupiter.

This includes information about you that you provide to us. The nature of the services you are requesting will determine the kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list):

  • basic Personal Data (such as first name; family name; job title; company name; company email address; business phone number; business address; city; postcode; country).

Information that we collect or generate about you.

This includes (by way of non-exhaustive list):

  • a file with your client records and contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the services which we have provided to you; and
  • details of site and marketing/communication preferences.

Information we obtain from other sources.

This includes:

Cookies

  • When you visit Jupiter Websites, cookies are used to collect information about the services that you use, and how you use them. Cookies are essentially a small amount of data which is transferred to and sometimes updated on your computer or other devices by our web servers.
  • For more information on the cookies used by Jupiter please see our Cookie Policy on our website.
Analytics
  • We may obtain publicly available data from social media as part of our use of analytics tools provided by social media sites, including Twitter. We do not deliberately identify individuals in these data sets (although they may contain some Personal Data) and do not combine it with other data. We do not share this data with any third parties.

Anonymised data

  • In addition to the categories of Personal Data described above, Jupiter will also process further anonymized information and data that is not processed by reference to a specific individual.

4. How we use your information

4.1     Your Personal Data may be stored and processed by us in the following ways and for the following purposes:
  • for ongoing review and improvement of the information provided on Jupiter Websites to ensure they are user friendly and to prevent any potential disruptions or cyber-attacks;
  • to conduct analysis required to detect malicious data and understand how this may affect your IT system;
  • for statistical monitoring and analysis of current attacks on devices and systems and for the on-going adaptation of the solutions provided to secure devices and systems against current attacks;
  • for in-depth threat analysis;
  • to understand your needs and interests, including to tailor the content of our marketing;
  • for the management and administration of our business;
  • for market analysis;
  • to allow you to use and access the functionality provided by the Jupiter Products;
  • to assess your application for Jupiter Products, where applicable;
  • to set up customers to use Jupiter Products;
  • to understand feedback on Jupiter Products and to help provide more information on the use of those products and services quickly and easily;
  • to communicate with you in order to provide you with services or information about Jupiter and Jupiter Products;
  • in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or
  • for the administration and maintenance of databases storing Personal Data.

4.2     However we use Personal Data we make sure that the usage complies with law and the law allows us and requires us to use Personal Data for a variety of reasons, including but not limited to the following:

  • in order to perform our contractual obligations;
  • where we have obtained your consent;
  • where we have legal and regulatory obligations that we have to discharge;
  • where we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
  • the use of your Personal Data as described is necessary for our legitimate business interests, such as:
    • allowing us to effectively and efficiently manage and administer the operation of our business;
    • analysing market events;
    • marketing our products and services;
    • maintaining compliance with internal policies and procedures;
    • monitoring the use of our copyrighted materials;
    • enabling quick and easy access to information on Jupiter Products;
    • offering optimal, up-to-date security solutions for mobile devices and IT systems; and
    • obtaining further knowledge of current threats to network security in order to update our security solutions and provide these to the market.
4.3    We will take steps to ensure that the Personal Data is accessed only by employees of Jupiter that have a need to do so for the purposes described in this Privacy Notice.

5. Disclosure of your information to third parties

5.1      We may share your Personal Data within the Jupiter Group for the purposes described above. This will include our subsidiaries and affiliated companies.

5.2      We may also share your Personal Data outside of the Jupiter Group for the following purposes:

  • with other trusted businesses or persons for the purpose of processing personal data on our behalf for the above stated purposes. These will include any depositary, stock exchange, clearing or settlement system, counterparties, dealers, custodians and others where disclosure of your Personal Data is reasonably intended for the purpose of effecting, managing or reporting transactions or estab