JB Capital

PRIVACY POLICY REGARDING THE RESEARCH PORTAL OPERATED BY FACTSET – JB Capital

Last Revised on: November 2020

This Privacy policy (hereinafter, the “Policy”) regulates the processing of User personal data by JB Capital Markets, Sociedad de Valores, S.A.U. (henceforth, “JB Capital”) through the websites research.jbcm.com and research.jbcapital.com (hereinafter, the “Website”).

1.- Identity and contact details of the Data Controller

In accordance with Regulation (EU) 2016/679 (hereinafter, “ GDPR”) and Spanish Organic Law 3/2018, of December 5, on the Protection of Personal Data and the guarantee of digital rights (henceforth, “LOPDGDD”), the User is hereby informed that the Data Controller responsible for the processing of his/her personal data is JB Capital, a company incorporated under the laws of Spain, with registered office at Calle Serrano Anguita, 1, 28004, Madrid, and Tax ID number A-85214922.

In the event that the User has any questions regarding the processing of his/her personal data, he/she may contact the DPO of JB Capital at the following email address lopd@jbcapital.com

2.- Purposes, Lawful bases for the processing of User personal data and retention periods

Users are hereby informed that JB Capital may process their personal data for the following purposes:

Purpose	Lawful basis	Retention period
1. Enabling access to the Research portal.- This purpose allows JB Capital to process User personal data (email address) to provide him/her with access to the research portal.	Processing is necessary for the performance of a contract to which the User is party [Article 6(1)(b) GDPR] The User must accept the Terms & Conditions of the Research Portal prior to entering the Website. Acceptance will take place during the on boarding process that is conducted by JB Capital. After the on boarding process, JB Capital will provide the user with credentials to access the Platform. The accepted Terms & Conditions shall govern User interaction with the portal.	JB Capital may process User personal data for the duration of his/her condition as registered User of the Website and/or until he/she requests cancellation or erasure of his/her Personal Data. Subsequently, JB Capital may retain User personal data, duly blocked, for a period of 5 years after the end of the contractual relationship (either due to cancellation matters or because the User is no longer registered in the Portal)
2. Elaborating statistical reports based on user readership of the Website contents. This purpose allows JB Capital to collect User personal data (email) to track and statistically analyse readership data related to the contents of the platform. The collected readership information will be used in the drafting of general statistical reports related to the overall user readership with the platform contents with the purpose of improving the Portal functionalities.	JB Capital has a legitimate interest in analysing general user readership data of the platform contents to improve the services it offers. [Article 6(1)(f) GDPR]	JB Capital will anonymise the collected personal data and draft the reports in accordance to statistical and not individual values, to ensure that Users cannot be identifiable. After the data is duly anonymised, JB Capital may process the statistical data indefinitely.
3. Manage and resolve inquiries and other User requests through the Website’s “Contact Us” channel. This purpose allows JB Capital to process User personal data to resolve any inquiry (regardless of its nature) that Users may have regarding the Portal.	Consent [Article 6(1)(a) GDPR] Consent shall be deemed to have been granted by the User when he/she ticks the consent box provided in the ‘ Contact Us’ form.	JB Capital may process User personal data until settlement or resolution of the relevant incident and/or enquiry. Subsequently, JB Capital may retain User personal data duly blocked for a period of 5 years.

In accordance with both GDPR and LOPDGDD, JB Capital will process User personal data for the purposes set above. Once these purposes become unnecessary or have terminated, JB Capital will keep User personal data duly blocked for the retention periods that are also displayed above. The blocking of personal data implies that JB Capital may only process User personal data collected for any of the above purposes to address any liabilities that may arise in connection to said purposes. JB Capital guarantees to delete User personal data upon termination of the above retention periods.

3.- Security Measures

JB Capital has adopted the levels of security for the protection of personal data legally required by the regulations in force and has installed adequate technical and organisational measures with the objective of guaranteeing the security of User personal data. As such, JB Capital security measures have been designed to protect User personal data against its destruction, loss, misuse, alteration, unauthorised access and/or theft. JB Capital has designed its security measures on the basis of criteria such as the scope, context, purposes of the processing, current state of the art and the existing risks of every individual processing activity.

4.- Personal data recipients:

JB Capital will not transfer User personal data to any third party. Nevertheless, some entities subcontracted by JB Capital may have access to User personal data and information as JB Capital Data Processors. These entities will only process User personal data on behalf of JB Capital, in accordance with JB Capital instructions and in strict compliance with statute law. The Data Processors that may access user personal data as Data Processors in the context of the research portal are:

- FactSet UK Ltd. This entity will have access to User personal data to provide services related to the management (including maintenance) of the research portal.

In this regard, and to ensure the above, JB Capital has ratified a Data Protection Agreement with all of its Data Processors before providing said third parties with access to User personal data.

5.- Data subject rights

Users may exercise any of the rights set out below before JB Capital. In order to exercise such rights, Users must send a request, together with a copy of your ID card Passport or equivalent document, to the following e-mail address: lopd@jbcapital.com If the request does not meet the necessary requirements, Users are hereby informed that JB Capital may request its amendment.

Right	Description
Right of access	Consult what User personal data is being processed by JB Capital.
Right to rectification	Modify the personal data that is being processed by JB Capital when said data is inaccurate.
Right to object	Request JB Capital not to process Users’ personal data for certain specific purposes.
Right to erasure	Request JB Capital to remove Users’ personal data.
Right to restriction of the processing	Request JB Capital to limit the processing of Users’ personal data.
Right to data portability	Request JB Capital to provide Users’ with their information in a computer readable format.

Additionally, if Users consider that JB Capital has not adequately dealt with their data subject rights request, they may lodge a complaint against JB Capital before the competent Supervisory Authority.

6.- Use of Cookies by the Website

6.1 What is a cookie?

Cookies are small text files that are installed in the User’s browser. The objective of the installation of cookies depends on the type of cookie that is installed in the User’s browser. Some cookies record User activity on the Website while others are essential for the functioning of the Website. In addition, other cookies may be able to offer Users are more personalized navigation through the Website or display videos and interactive graphics within said Website.

6.2 What type of cookies does this Website install?

Cookies that may be installed in the User’s device can be classified according to the following criteria:

6.2.1 Owners of the cookies that may be installed

The cookies that may be installed in the Users’ browser are owned by:

- Third parties (FactSet UK Ltd.). - Cookies owned by third parties are sent to the User’s browser or device from a computer or domain that is not managed by JB Capital but by another (external) entity.

6.2.2 Purpose of the cookies that may be installed

As mentioned in Section 6.1 above, there are different types of cookies for different types of use. As such, this Website may install the following cookies in the Users’ browsers:

- Strictly necessary cookies or Technical cookies: These types of cookies are necessary for the adequate operation of the Website. For instance, strictly necessary cookies will allow you to connect to secure areas of the Website.

6.2.3 Retention period of the cookies that may be installed

According to the retention period of the cookies installed in the Users’ browser, this Website may install:

- Session cookies: These cookies retain User data for the time he/she remains in the Website. As such, data that is subject to session cookies will disappear when the User leaves the session and/or website.

6.3 Specific type of cookies that may be installed in the User’s browser or device

Name	Owner	Purpose	Retention period
PHPSESSID	FactSet UK, Ltd.	To store the logged in user's username and an encrypted password. This information is required to allow the User to remain logged in to the Website without needing to submit his/her username and password during his/her session navigation.	Session

6. 4. How can Users decide what cookies are installed on their browsers?

Users may set their browsers and devices to reject, block and, if necessary, delete cookies. To adequately perform any of the above actions in the main internet browsers, please follow the procedures set below:

(i) Internet Explorer: Tools -> Internet Options -> Privacy -> Settings.
(ii) Firefox: Tools -> Options -> Privacy -> History -> Customised settings.
(iii) Chrome: Settings -> Show advanced options -> Privacy -> Content settings.
(iv) Safari: Preferences -> Security.

Without limiting the foregoing, Users are hereby informed that technical cookies must always be installed in the Users’ browser, as these types of cookies are responsible for guaranteeing the adequate functioning of the Website. Users may however decide not to install technical cookies by blocking or deleting cookies through the procedure enshrined in the above paragraph. In case the User voluntarily uninstalls technical cookies from its browser, JB Capital cannot guarantee the adequate functioning of its Website and as such, shall not be responsible for any defects or errors that may occur within the Website and/or affect the User.