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      Privacy

      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, as relevant (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 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.

      1.4     This website is not intended for children. We do not knowingly collect data relating to children.

      1.5     We keep our privacy policy under regular review.

      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”):

      Information we receive through our websites (“Jupiter Websites”);

      Information we receive through our fund related products (“Jupiter Products”); and Information we receive through our support, mobile security solution or cloud-based services (“Jupiter Services”).

      3.  The types of personal data we collect
       

      Purpose / processing activityType of dataLawful basis

      To onboard you as a new customer, to manage our relationship with you

      Basic contact details (first name, last name, job title, company name, email address, phone number, address)

      KYC information as appropriate (Criminal Records Bureau checks, passport details, utility bills)

      Performance of a contract with you

      Compliance with our legal obligations

      To administer and protect our business and this website (including (i) analysis,   testing, maintenance,   support, reporting and hosting of data, and (ii) using data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our        communications and marketing)Name, contact details, IP address, login data, browser type, operating system, website usage

      Legitimate interests – (i) business administration in relation to our website and IT networks including security and (ii) study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy

      Compliance with our legal obligations 

      To make enquiries with you to ensure you are satisfied with our servicesBasic contact details (first name, last name, job title, company name, email address, phone number, address); client records contact historyPerformance of a contract with you

      Legitimate interests – understanding how our customers use our products/services, to develop them and grow our business

      To send you information about Jupiter Products in which you may be interested

      Name, email address

      Consent if information about Jupiter Products is directed to individuals and a “soft opt-in” where information is sent on related products. One key exemption relates to business-to-business marketing. When sending emails to corporate email addresses we will rely on legitimate interests (rather than consent) as the lawful basis for sending information about Jupiter Products.

      To send you marketing communicationName, email addressConsent if marketing is directed to individuals. One key exemption relates to business-to-business marketing. When sending emails to corporate email addresses we will rely on legitimate interests (rather than consent) as the lawful basis for sending communications

      3.1 General uses

      3.1.1 We may also process your personal data where: we have legal obligations that we have to discharge;

      3.1.2 you have consented to such use; and/or

      3.1.3  to establish, exercise or defend our legal rights for the purposes of legal proceedings.

      If you do choose to provide your consent, you can withdraw it at any time by contacting us (section 10).

      We will keep this data only for as long as necessary depending on the purpose for which it was provided.

      4. Use of Artificial Intelligence

      4.1                       We use artificial intelligence (“AI”) technologies to operate, secure, and improve our services and to assist users and staff. This AI may process information you provide, usage data, and content generated in the service.

      4.2                       We do not allow providers to train public models on your personal information without authorisation.

      4.3                       Significant decisions are not made solely by automated decision making without appropriate safeguards.

      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 establishing a relationship with a view to such transactions;
      • with our business partners. For example, this could include our partners from whom you or your company or your organisation purchased the Jupiter product(s). Personal Data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;
      • with third-party agents and contractors, or potential third party agents and contractors, for the purposes of providing services to us (for example, Jupiter's accountants, professional advisors, IT and communications providers, credit reference agencies, debt collectors and outsourced middle office service providers). These third parties will be subject to appropriate data protection obligations and they will only use your Personal Data as described in this Privacy Notice;
      • with representatives, agents, custodians, intermediaries and/or other third party product providers appointed by the Client or prospective Client (such as accountants, professional advisors, custody service providers and product providers);
      • to the extent required by law, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend its legal rights;
      • if we sell our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes;
      • if we sell, transfer, or merge parts of our business or assets. In such cases, the new owners may use your personal data as described in this privacy policy; and
      • where you are a joint account or portfolio holder (or otherwise one of multiple persons holding an account or portfolio), we may disclose your Personal Data to the other joint account or portfolio holder or other person.

      6. International transfers of personal data

      6.1                       Jupiter is a global business. Our customers and our operations are spread around the world. As a result we collect and transfer Personal Data on a global basis. That means that we may transfer your Personal Data to locations outside of your country.

      6.2                       Where we transfer your Personal Data to another country, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of the UK or Europe, for example, this may be done in one of the following ways:

      • the country that we send the data to might be approved as offering an adequate level of protection for Personal Data;
      • the recipient might have signed up to a contract based on the ICO’s international data transfer agreement or addendum, or the European Commission’s standard contractual clauses obliging them to protect your Personal Data; or
      • in other circumstances the law may permit us to otherwise transfer your Personal Data outside the UK or Europe.

      6.3                       You can obtain more details of the countries we transfer data to and of the protection given to your Personal Data referred to above (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described in section 10 below.

      7. How we safeguard your information

      7.1                       We use technical and organisational measures to protect your personal data from loss and unauthorised access. We have procedures to handle suspected data breaches and will notify you and relevant regulators if required by law. Employees, agents, contractors, and third parties processing your data will do so under our instructions and are bound by confidentiality.As a condition of employment, Jupiter employees are required to follow all applicable laws and regulations, including in relation to data protection law. Unauthorised use or disclosure of confidential client information by a Jupiter employee is prohibited and may result in disciplinary measures.

      7.2                       Internet data transmission is not completely secure. While we strive to protect your data (e.g., by encrypting outgoing emails), we cannot guarantee security during transmission to our website. Any internet data transmission is at your own risk. Once we receive your data, we use procedures and safety features to prevent unauthorised access.

      8. How long we keep your personal data

      8.1                       How long we will hold your Personal Data for will vary and will be determined by the following criteria:

      • the purpose for which we are using it - Jupiter will need to keep the data for as long as is necessary for that purpose; and
      • legal obligations - laws or regulation may set a minimum period for which we have to keep your Personal Data.

      9. Your rights

      9.1                       In all the above cases in which we collect, use or store your Personal Data, you may have the following rights:

      • your right of access - you have the right to ask us for copies of your personal data. You can request other information such as where we get personal data from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here;
      • your right to withdraw consent - when we use consent as our lawful basis you have the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation. You can read more about this right here;
      • your right to data portability - you have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here;
      • your right to rectification – you have the right to request that we rectify or delete your Personal Data if it is inaccurate or incomplete. You can read more about this right here;
      • your right to restriction of processing - you have the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request. You can read more about this right here; and
      • your right to object to processing - you have the right to object to the processing of your personal data. You can read more about this right here.

      9.2                       You can exercise your rights by contacting us using the details listed in section 10 below.

      9.3                       In most cases, you can exercise your rights free of charge. We may charge a reasonable fee if your request is clearly unfounded, excessive, or if you request multiple copies of the information. In some cases, we may refuse to comply with such requests.

      9.4                       We aim to respond to all legitimate requests within one month. If your request is complex or you have made multiple requests, it may take longer. We will notify you and keep you updated in such cases.

      9.5                       We may request specific information to confirm your identity and your right to access the data. This ensures that personal data is not disclosed to unauthorised individuals. We may contact you for further information to expedite our response.

      9.6                       It is important that the personal data we hold about you is accurate and current. Please inform us (by contacting us (section 10)) of any changes to your personal data during your relationship with us, such as a new address or email.

      10. Questions and concerns

      10.1                       If you have any questions or concerns about Jupiter's handling of your Personal Data, or about this notice, please contact The Data Protection Officer using the following contact information:

      Address: The Data Protection Office, The Zig Zag Building, 70 Victoria Street, London, SW1E 6SQ

      Email Address: DPO@jupiteram.com

       

      10.2                       We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, we will provide you with the contact information for that regulator.

      Last review: February 2026

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