Privacy Policy

1. Information We Collect

We collect information you provide directly to us, information collected automatically when you use our platform, and information we receive from third parties.

Information You Provide Directly

When you submit a deal inquiry, create an account, or contact us, we may collect:

• Name, email address, telephone number, and mailing address
• Company name, title, and professional credentials
• Transaction details, including property descriptions, loan amounts, asset valuations, and business plans
• Financial information relevant to your financing request, such as income statements, rent rolls, and tax records
• Identity verification documents as required by applicable regulations
• Communications you send us via email, web form, or through the client portal

Information Collected Automatically

When you visit our website, we automatically collect certain technical information, including:

• IP address, browser type, operating system, and device identifiers
• Pages viewed, time spent on pages, referring URLs, and navigation paths
• Cookie identifiers and similar tracking technologies (see our Cookie Preferences page for details)
• Approximate geographic location derived from IP address

Information from Third Parties

We may receive information about you from lenders in our network, business verification services, credit reporting agencies (where applicable and permitted), and publicly available professional directories.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Service Delivery: To evaluate your financing request, match you with appropriate lenders, prepare presentation materials, and manage the advisory process through to closing.
• Client Communication: To respond to your inquiries, provide updates on your transaction, and send information relevant to your financing request.
• Account Management: To create and maintain your client portal account, authenticate your identity, and ensure secure access to your deal information.
• Compliance and Legal Obligations: To comply with applicable anti-money laundering (AML) and know-your-customer (KYC) requirements, financial regulations, and lawful requests from government authorities.
• Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, identity theft, and other illegal activity.
• Platform Improvement: To analyze usage patterns, identify technical issues, and improve the functionality and user experience of our website and client portal.
• Marketing (with consent): To send you information about our services, market updates, and relevant industry content, where you have consented or where we have a legitimate interest in doing so.

3. Sharing of Your Information

We do not sell your personal information. We share your information only in the following circumstances:

With Lenders in Our Network

The core of our service involves presenting your deal to institutional lenders. We share your transaction information and sponsorship materials with lenders who have been vetted by JP Windsor and who are potentially positioned to provide the financing you seek. We share only the information necessary for the lender to evaluate and potentially quote on your transaction. Lenders receive your information pursuant to their own privacy policies and applicable regulatory obligations.

With Service Providers

We engage third-party service providers to support platform operations, including cloud hosting providers, document management services, email delivery systems, and analytics platforms. These providers access your information only to perform services on our behalf and are contractually prohibited from using it for other purposes.

For Legal and Compliance Purposes

We may disclose your information when required by law, regulation, court order, or lawful request from a governmental authority; when necessary to protect the rights, property, or safety of JP Windsor, our clients, or others; and in connection with fraud investigations or legal proceedings.

In Connection with Business Transfers

If JP Windsor is involved in a merger, acquisition, asset sale, or restructuring, your information may be transferred as part of that transaction. We will notify you of any such transfer and any changes to this Privacy Policy.

4. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this policy, to comply with legal obligations, and to resolve disputes. Specifically:

• Deal information for transactions that close is retained for a minimum of seven years to satisfy regulatory record-keeping requirements.
• Deal information for transactions that do not close is retained for up to three years from the date of last activity, after which it is deleted or anonymized.
• Account information is retained for the duration of your active account plus two years following account closure.
• Marketing consent records are retained as required to demonstrate compliance with applicable opt-in requirements.

5. Security Measures

We implement technical and organizational measures designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit and at rest, access controls limiting information access to authorized personnel with a legitimate need, secure authentication requirements for the client portal, and regular security assessments of our infrastructure.

No security system is impenetrable. In the event of a data breach that affects your personal information, we will notify you as required by applicable law.

6. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights with respect to your personal information:

• Access: The right to request a copy of the personal information we hold about you.
• Correction: The right to request correction of inaccurate or incomplete personal information.
• Deletion: The right to request deletion of your personal information, subject to our legal retention obligations.
• Restriction: The right to request that we restrict processing of your personal information in certain circumstances.
• Portability: The right to receive your personal information in a structured, machine-readable format.
• Objection: The right to object to processing of your personal information for direct marketing purposes.
• Withdrawal of Consent: Where processing is based on consent, the right to withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at info@jpwindsor.us with the subject line "Privacy Rights Request." We will respond within the timeframe required by applicable law, typically within 30 days.

7. California Privacy Rights

California residents have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). These rights are described in detail on our Your Privacy Choices page. We do not sell or share personal information as those terms are defined under California law for purposes of cross-context behavioral advertising without your opt-in consent.

8. International Data Transfers

JP Windsor operates across the Americas. If you are located outside the United States, your personal information may be transferred to and processed in the United States, where data protection laws may differ from those in your jurisdiction. We implement appropriate safeguards for such transfers in accordance with applicable law.

9. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by posting the updated policy on this page with a revised effective date and, where required by law, by providing additional notice. Your continued use of our services after the effective date of any update constitutes acceptance of the revised policy.

10. Contact for Privacy Concerns

For questions about this Privacy Policy, to exercise your privacy rights, or to report a privacy concern, contact us at:

JP Windsor Private Capital
Privacy Office
info@jpwindsor.us