Corporate Privacy Policy

In this policy, the terms “we”, “us”, “our(s)”, and “Company” refer to Jefferson Capital Holdings, LLC and its affiliates (“JCAP”). Sections 4-7 apply to Company affiliates designated in Section 4 and to information processed on accounts established in the European Economic Area (EEA) or the United Kingdom. Section 8 applies to Company affiliates in Canada, as designated in Section 8. All other sections of this policy apply to the Company and all affiliates.

Section 1: Overview

The Company respects individual privacy and values the confidence of its customers, employees, consumers, business partners, and others. Not only does the Company strive to collect, use, and disclose Personal Information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. We have therefore adopted a privacy and data protection policy that is applicable to information relating to our employees as well as to information relating to other individuals collected or processed in the general course of our business, including but not limited to Personal Information received from locations within the European Union and Canada.

Section 2: Scope

This Policy applies to any Personal Information received by the Company in any format, including electronic, paper or verbal.

Section 3: Definitions

For purposes of this Policy, the following definitions shall apply:

Section 4: Data Privacy Framework (DPF) Affiliates

The following company affiliates adhere to the DPF Principles and may collect the same types of EU or UK data as the Company:

Section 5: EU-U.S. Data Privacy Framework

The Company complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. The Company has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union or United Kingdom (including Gibraltar) in reliance on the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/ https://www.dataprivacyframework.gov/.

Section 6: EU-U.S. Data Privacy Framework Principles

NOTICE:

Where the Company collects Personal data directly from individuals in the EEA or the United Kingdom, we will inform them of the following:

To ensure fair and transparent processing of personal data the Company will also provide the following information:

Where the personal data was not obtained from the data subject, the following information will be supplied in addition to the information set out above:

Where the Company intends to further process the personal data for a purpose other than that for which the personal data were obtained the Company shall provide the data subject prior to that further processing with information on that other purpose.

Where the Company receives Personal Information from its subsidiaries, affiliates or other entities in the EEA or the United Kingdom, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such Personal Information relates.

CHOICE:

The Company will offer the opportunity to choose whether their Personal Information is to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. The Company will provide clear and informed methods to exercise their choices.

ONWARD TRANSFER:

In cases of onward transfer to third parties of data of EU or United Kingdom individuals received pursuant to the EU-US Data Privacy Framework, the Company is liable unless we can prove we were not a party to the events giving rise to the damages. The Company will obtain assurances from its Agents that they will safeguard Personal Information consistently with this Policy. Examples of appropriate assurances that may be provided by Agents include: a contract obligating the Agent to provide at least the same level of protection as is required by the relevant DPF Principles, Data Privacy Framework certification by the Agent, or being subject to another European Commission adequacy finding. Where the Company has knowledge that an Agent is using or disclosing Personal Information in a manner contrary to this Policy, the Company will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION:

Upon request, the Company will grant reasonable access to Personal Information that it holds. In addition, the Company will take reasonable steps to permit Consumers and Employees to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

SECURITY:

The Company will take reasonable precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to Personal Information to employees who need to know that information to provide services. We maintain physical, electronic and procedural safeguards that comply with applicable laws to guard Personal Information.

DATA INTEGRITY:

The Company will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. The Company will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete, and current.

ENFORCEMENT:

The Company is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Any Employee that the Company determines is in violation of this policy may be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION:

Any questions or concerns regarding the use or disclosure of Personal Information should be directed to ‘Department Privacy’ at the address given below. In compliance with the EU-US Data Privacy Framework EU-U.S. DPF and the UK Extension, to the EU-U.S., The Company commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the U.S. pursuant to the EU-U.S. DPF. Individuals with inquiries or complaints should first contact the Company at:

Department Privacy
200 14th Avenue E
Sartell, MN 56377
USA
Privacy@JCap.com

The Company has further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, DATA PRIVACY FRAMEWORK SERVICES, operated in the U.S. by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you. If your DPF complaint cannot be resolved through these above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. Seehttps://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf.

Section 7: Limitation on Application of Data Privacy Framework Principles

Adherence by the Company to these DPF Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

Section 8: Canadian Privacy Policy

The handling and protection of personal information in Canada is covered by the Federal Personal Information Protection and Electronics Act (PIPEDA) and applicable provincial privacy legislations and can be found for Canaccede Financial Group Ltd. and its subsidiaries, including without limitation Canaccede International Management Ltd., here: https://www.canaccede.com/privacy-policy/ and Fidem Finance Inc. here: https://fidemfinance.ca/privacy-policy/.

Section 9: What information do we collect?

Information provided to us to enable us to contact you. Examples may include name, email address, mailing address, telephone number, etc. Contact information may identify you personally.

Information you may provide to us, which may include credit card number, bank information, billing address, billing contact name, telephone numbers, email address, etc. Billing information may identify you personally.

Information that allows you to access the services we provide, technical support, ticketing system and any third-party services provided through us. Examples may include user ID, invitation number, account number, access and permission levels, password, etc. Password information does not identify you personally, but it may when associated with other information.

Information that allows us to configure the services we provide so that they are more easily provided to you. Examples may include your IP address, browser type, referring/exit pages, operating system, affiliate id, etc. Technical information does not identify you personally, but it may when associated with other information.

Some information about your IP address, web browser, and computer system are automatically transmitted to our web servers as an integral part of the operation of the Internet. Thus, if you use our internet site(s) after reviewing the terms of use and/or receiving proper disclosure, we reserve the right to automatically collect and/or track: 1) The home server domain names, email addresses, type of computer, and type of web browsers of visitors to our web site and 2) Information on what pages of our web site visitors’ access. Internet data does not identify you personally, but it may when associated with other information.

Information you choose to provide to us and that is not necessary for the operation of the services we provide. Examples may include acceptance of an offer extended to you, your endorsement of us and your connections to us in social networks, etc. It is your decision whether you include information that identifies you personally when you provide voluntary information to us.

Section 10: How do we use the information we collect?

We may collect non-public personal information about you as permitted by law from:

We may disclose non-public personal information about you to third parties, such as business partners, vendors, and credit reporting agencies. We will disclose information about you only to the extent that it is: (a) specifically directed by you; (b) permitted by applicable law and (c) not prohibited by other applicable law.

We use your Personal Information to send you information about our company, process requests for services, and to contact you when necessary. You will be permitted to opt out prior to using your Personal Information for any other purpose. We also may be required to disclose an individual’s Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. We may also use the information we collect to improve the content of our website(s)

Section 11: Method to access and ability to correct personal information

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query via email to Privacy@JCap.com. If requested to provide or remove data, we will respond within a reasonable timeframe or within the timeframe as required by applicable law.

Section 12: Online Privacy

COOKIES:

We may use cookies to keep track of your interaction and time spent on this site(s) or related websites. We may also use them to recognize return visitors and to track our promotions. We may collect personally identifiable information from visitors in the way of online forms but only where visitors volunteer such information. We may also collect information about how visitors interact with our website. This information may be obtained through the analysis of server logs and through the use of “cookies” placed on user machines. A cookie is a piece of software that a web server can store on a computer system to identify the visitor if they visit the website again. All of the information that we collect through the use of cookies from visitors is not personally identifiable. However, it may be associated with personally identifiable information that visitors provide us through our website(s). We gather this information for internal use only and will never authorize the release of this information with anyone outside of our company. Most browsers are initially configured to accept and process cookies. You can configure your browser to refuse cookies, however, certain online interactions may be negatively affected by such a configuration. Most browsers allow you to configure them to notify you when you receive a cookie and to thereby allow you to decide whether to accept that cookie. We reserve the right to use cookies on our website(s).

INTERNET DATA SECURITY AND INTEGRITY:

We make every effort to follow industry standard security measures to prevent the loss, misuse and alteration of the information under our control. However, no information transmitted on the internet or stored on servers is 100% secure. Fraudulent people exist, software and hardware can malfunction, and people make mistakes. As a result, we cannot guarantee that any information covered by this Policy will be absolutely secure.

DO NOT TRACK BROWSER REQUESTS:

At this time, we do not respond to “do not track” signals sent from browsers.

Section 13: SMS/Text Messaging

To facilitate consumer preference in a digital environment, our SMS Outreach (SMS/TXT program/system) provides efficient two-way communication. By providing your mobile number, you give permission to send you account-related text messages, like payment reminders and notifications, in conjunction with the services we provide.

Section 14: Contact Us

If you have questions regarding this Policy or about the privacy practices of the Company, please contact us at: Privacy@JCap.com.

Section 15: Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will post our Privacy Policy on our website(s) and will update the ”Effective“ date to reflect the date of any changes and to reflect a review that occurs at least annually.

Effective October 29, 2024