JCR Capital Investment Corp. (JCR Capital) adopted this policy with recognition that protecting the privacy and security of the nonpublic personal information we obtain about our sponsors, clients and investors is an important responsibility. We also know that you expect us to service you in an accurate and efficient manner. To do so, we must collect and maintain certain nonpublic personal information about you or your business. We want you to know what information we collect and how we use and safeguard that information.
WHAT INFORMATION WE COLLECT
We collect certain nonpublic personal information about you or your business (such as your name, address, social security number, EIN or other financial information, etc.) that you provide on client or subscription agreements, custodian or brokerage applications, or other forms as well as communications (electronic, telephone, written or in person) with you or your authorized representatives (such as your attorney, accountant, etc.). We also collect information about your accounts with us to manage your accounts, and on sponsors and guarantors regarding certain business and financial information during the investment/loan origination due diligence process, including the provision of comprehensive background checks if applicable.
WHAT INFORMATION WE DISCLOSE
JCR Capital does not sell the nonpublic personal information we collect about our sponsors, clients and investors to anyone. We regularly (and have within the past 12 months) disclose such information to third parties only: (1) in furtherance of our business relationship with clients, and then only to those persons necessary to effect the transactions and provide the services that clients authorize (such as broker-dealers, administrators, custodians, independent managers, etc.); (2) to persons assessing our compliance with industry standards (e.g., professional licensing authorities, etc.); (3) our attorneys, accountants, and auditors; or (4) as otherwise provided by law.
SECURITY OF YOUR INFORMATION
We restrict access to your nonpublic personal information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect your nonpublic personal information.
Our policy about obtaining and disclosing information may change from time to time. We will provide you notice of any material change to this policy before we implement the change.
OPTING OUT /RIGHT TO REQUEST DELETION OF INFORMATION
- Sponsors, clients and investors cannot opt out of allowing JCR Capital to share their nonpublic personal information with affiliated or non-affiliated third parties which are necessary to service their accounts or conduct investment due diligence. Although we do not share your information for marketing purposes, or sell your information, if you would like to opt out of any disclosure of your information to non-essential third parties (except for regulatory purposes), please contact Mr. Erwin at the address below. To comply with the Investment Advisers Act of 1940, JCR is generally prohibited from deleting business records for a minimum of five years. If you would like to submit a request to know or a request to delete request information containing your nonpublic personal information (after the regulatory period), please call 855-550-0007 or complete the form available through the link: https://www.lighthouse-services.com/walkerdunlop/privacy .
REQUESTS FOR INFORMATION
JCR Capital Investment Corp.
Stephen Erwin, CCO
1225 17th Street, Suite 1660
Denver, CO 80202