Privacy Notice
Last updated: January 2024
PLEASE READ THIS PRIVACY POLICY CAREFULLY. Your privacy is very important to us. Jukebox Technology LLC, located at 10000 Washington Blvd, Suite 7-134, Culver City, CA 90232 (together with its subsidiaries and other affiliated entities, " JKBX") is committed to maintaining your privacy. This privacy notice (the "Privacy Notice" ) is intended to inform you of:
The types of information we collect
How we use information we collect
How we share information we collect
How we safeguard information we collect
Other important privacy information
This Privacy Notice applies to you whenever you access or use any domains or subdomains of our website at https://marketing.jkbx.com/ (the " Platform"), or when you access, use or download any products, services, features, content, widgets, materials or other tools offered by JKBX (collectively, " Services").
Please note that your relationship with JKBX is also governed by our Platform Terms of Use and the transaction documents that you may enter into in connection with making an investment through our Platform. JKBX also has relationships with third parties for purposes of cookies served on our Platform, as detailed below. You are encouraged to carefully review these sections as well.
Types of Information We Collect
To provide our Services, and facilitate exchanges between users of the Platform, we obtain personal information directly from you and obtain information about you indirectly through electronic communications and third parties (collectively, "Personal Data").
User Supplied Membership Information
Depending on the Services you seek to access we may require that you provide some or all of the following types of Personal Data:
Name
Address
Email
Phone Number
Entity Information
SSN (or equivalent)
Financial Information
Joint Owner Information
Date of Birth
Accreditation Status
Employment
Citizenship
Payment Information
Investment Experience
Investment Suitability Information
Our membership registration process, surveys and questionnaires may request or require that you provide other information that you may, at your option, choose to provide or withhold. Any such information provided will be subject to this Privacy Notice.
Verification Information
If required to help us verify your identity, you may provide us a copy of your driver's license, passport or other government issued ID. If required to help us verify your residence, you may provide us with a utility bill, lease or other proof of residence. You may also provide us other verification documents, such as bank statements reflecting the source of funds, to meet U.S. Bank Secrecy Act or anti-money laundering laws, US Treasury department rules or regulations or other legal requirements. By providing the verification information and documents mentioned above, you also provide us information within those records, which may include characteristics of protected classifications like your sex, age, national origin, and citizenship.
Banking Information
In order to make an investment in securities offered through our Platform, you must provide us and our third party financial providers or partners with certain account and other payment information, such as information needed to make payment via ACH, wire, electronic checks, foreign currency or any other payment method accepted by us at such time. Our membership registration and buyflow process provides additional details on the types of payment information needed. For members who link or verify bank accounts over our Platform and/or one of these third-parties, you may further agree to your personal and financial information being transferred, stored, and processed by this third-party in accordance with their respective privacy policies.
Automatically or Passively collected Information
In addition to information you directly provide, we automatically or passively collect information when you access or use our services, such as, but not limited to, your IP address, device identifiers, click path, usage of our Platform and other electronic data. We may also record page views (hit counts), video content views, and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our Platform is being used, and for security and monitoring purposes. In order to determine whether your computer is supported by our system, we may collect additional technical information about your operating system and browser, as well as the presence of any software that our Platform may require to operate with your computer, or other third party software on your computer.
Cookies
Additionally, we may collect, store and use "cookies". A "cookie" is a small amount of data, often including an anonymous unique identifier, which is sent to your browser from a website's computers and stored on your computer's hard drive. Cookies can be used to provide you with a tailored user experience to make it easier for you to use a website upon a future visit, as well as to help you navigate between pages efficiently. We may include cookies on our Platform and use them to recognize you when you return to our Platform. You may set your browser so that it does not accept cookies. However, cookies must be enabled on your web browser if you wish to access certain personalized features of our Services. You can manage our use of cookies by clicking “Cookie Preferences” at the bottom of this webpage or via your browser settings. Note, each browser or device may require a different setting and we recommend reviewing browser or device specific information on how to adjust cookie settings. We encourage you to carefully review this section in order to learn more, and explore your opt-out options for certain cookies that are not necessary to become a member on our Platform.
A list of cookies we use can be found by clicking “Cookie Preferences” at the bottom of this webpage. Our uses of cookies fall into the following general categories:
Essential: These cookies are required for the operation of the service.
Advertising: These cookies help serve content that is relevant to you.
Analytics & Customization: : These cookies analyze usage for site optimization.
Performance & Functionality: These cookies facilitate the measurement and analytics for improved browsing experience.
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How Do I Control Cookies
There are multiple ways to control how cookies are used on your JKBX platform and your devices.
Cookies within the JKBX Platform. By using the JKBX Platform, you consent to the use of types of cookies detailed herein.
Advertising ID. You can customize your device settings to control advertising ID:
On Apple devices: enable "Limit Ad Tracking" in your device settings.
On Android devices: enable "Opt out of Ads Personalization" in device settings.
Third Party Cookies Opt-Outs. Many of the third-party and social media cookies as listed above also prove opt-outs on their own websites. You can find details on their own policies, as listed above in our cookies used.
Please note that removing or rejecting all cookies could affect the functionality of the Platform and its services.
For more information about cookies, please visit www.allaboutcookies.org if you are located within the United States. If you are located within Europe, visit www.youronlinechoices.eu.
Pixels
We may also use so-called "pixel tags" – small graphic images (also known as "web beacons" or "single-pixel GIFS") – to tell us what parts of our website have been visited, inform us of the reach and efficacy of our advertisements, or to measure the effectiveness of searches customers perform on our Site. Pixel tags also enable us to send email messages in a format customers can read, they inform us whether emails have been opened, and whether a video has been viewed,to help ensure that our messages are of interest to our users.
Some web browsers transmit "do-not-track" signals to websites. At this time, our Services are not designed to respond to these signals or similar mechanisms from browsers.
We may send email messages that use a "click-through URL" linked to content on our Platform. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We track this click-through data to help determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked, simply do not click text or graphic links in the email, or notify us here.
Usage Information
We collect certain information about you when you visit the Platform and interact with any of our Services. We collect information about when you use Services, the pages within the Platform you visit, the links you click on, the type, size and names of files you upload or download, and the search terms you use. If you invite others to use the Platform, we retain information about your referral.
We collect information in connection with the transactions you become a party to through our Services, including your participation in primary offerings via the Platform. Transaction data includes, without limitation, the terms on which you purchase securities and information relating to price, size, volume, class of securities, offers, acceptances, transfer restrictions, and any derivative data related thereto.
Third-Party Information
We collect information about you from third-party sources with which we maintain various commercial relationships. We utilize a third-party identity verification service provider to help us confirm your identity, prevent fraud, money-laundering and other illegal activity, and to satisfy legal requirements relating to the Services. We also receive information about you and your activities from third-party service providers, such as Google, LinkedIn, Meta, and other advertising, social media and market research partners who provide us with information about you, and/or your engagement with and interest in our Services. We may also receive information about you from our third-party marketing partners, under referral programs, IRA service providers, partnership agreements and/or under joint marketing arrangements.
How We Use Information We Collect
We may use your information for the following commercial purposes:
To administer, operate, facilitate and manage your relationship with JKBX and deliver the Services.
To facilitate our business operations, including fulfilling our legal and regulatory requirements such as identity verification, validation, anti-money laundering and "Know Your Customer" protocols.
To determine your eligibility to invest.
To enable you to subscribe for securities, make and receive payments and execute transactions.
To satisfy our record keeping obligations under applicable laws, rules and regulations.
To communicate with you about the Services and target our marketing, advertising and sales efforts to enhance your user experience and increase engagement. These communications may alert you to new Services, offerings, features, content and promotional events.
To provide you with information about our current Services, including onboarding materials, the availability and terms of new investment opportunities, reminders, information about your previous investments.
To verify your identity, accounts and activity, to monitor suspicious or fraudulent activity, and to identify violations of Service policies. We also use your information to debug, identify and correct errors;
On a de-identified, aggregated basis, for research and development activities, including to analyze how you use the Services to help us understand usage patterns and know if there are problems with the Services or areas ripe for improvement;
To contact you or, if applicable, your designated representative(s) by post, telephone, text message, electronic mail, facsimile, etc., in connection with your relationship with JKBX, including with information and updates about our Services.
In addition, if we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, creation of a trust or other affiliated entity, receivership or sale of JKBX' assets, or other corporate transaction affecting JKBX, your information may be shared, transferred or sold under a duty of confidentiality as part of a transaction as permitted by law or by contract.
By using the Services, you consent to receiving calls and messages, including auto-dialed and pre-recorded message calls, and SMS messages (including text messages) from us, at any telephone numbers that you have provided or may provide in the future (including any cellular telephone numbers). Your cellular or mobile telephone provider will charge you according to the type of plan you carry. You can "opt-out" of receiving these types of communications from us by following the directions provided elsewhere in this notice.
If your relationship with JKBX ends, we will continue to treat your Personal Data, to the extent we retain it, as described in this notice.
We do not sell or share personal identifying information from, to or with third parties for their direct marketing or similar purposes without your consent. We also do not offer financial incentives, preferential service agreements, or any other differences in our prices or Services in exchange for your information.
The manner in which partners, service providers and others with whom we share and/or disclose your information is governed by the policies of such parties, and we shall have no liability or responsibility for the privacy practices or other actions of any such parties. Generally, you can easily recognize when one of our partners is associated with a service. However, certain parties may provide services anonymously, and, in this case, we will only share information that is directly related to the applicable service(s). This may include the incorporation of your Personal Data into databases maintained to validate information for identity verification, including verification for anti-money laundering and "Know Your Customer" protocols.
The primary situations in which we share your data are as follows:
Partnering Arrangements: We employ other companies to perform functions on our behalf, such as service providers that assist in the administration of our Platform and our advertising and marketing efforts, identity verification services such as, data analytics companies that help us target our offerings, marketing partners, and custody and transfer agent services. We may need to share your information with these companies. These users may access this information so long as you are a member of the Platform.
Potential Business Combination: We may also transfer your Personal Data to a third party as a result of a business combination, merger, asset sale, reorganization or similar transaction or to governmental authorities when we reasonably believe it is required by law or appropriate to respond to a legal process. We will also share your information with third-party companies, organizations or individuals if we have a good faith belief that access, use, preservation or disclosure of your information is reasonably necessary to detect or protect against fraud or security issues, enforce our terms of use, meet any enforceable government request, defend against legal claims or protect against harms, our legal rights, or safety. In any such event, and to the extent legally permitted, we will notify you and, if there are material changes in relation to the processing of your Personal Data, give you an opportunity to consent to such changes. Any third party with whom we share your data with will be required to provide the same or equal protection of such data as stated in our Privacy Notice.
Service Providers: To operate the Services we share information about you as needed with our service providers, including financial institutions, broker-dealer(s), accountants, auditors, lawyers, payment processors, information technology consultants, advisors and our affiliates. We only share information to the extent it is required to fulfill our obligations to you and to regulators, and to operate the Platform and the Services. The information is only shared so long as you are a member or user of the Platform.
Affiliates: We do routinely share information with companies closely related to us – our "Affiliates" – for certain purposes under this notice. By "Affiliate," we mean an entity that controls, is controlled by, or is under common control with JKBX, whether the control results from equity ownership, contract, overlapping management or otherwise. In this context, "control" means the ability to replace the officers or directors or in some cases otherwise materially influence or control management decisions. Our Affiliates will be entitled to enjoy our rights under this Privacy Notice and we will be responsible for our Affiliate's conduct related thereto.
Regulators: We may share information about you with US, state or international regulators, where we believe doing so is required or appropriate to comply with any laws, regulations or other legal processes or law enforcement requests, such as court orders, search warrants, or subpoenas, including the requirements under the Federal Stored Communications Act ("SCA"), 18 U.S.C. Sections 2701-2712.
Third-Party Sites: The Platform may contain links to third party websites and may redirect you to third party websites. These sites include, among others, service providers who have a relationship with JKBX. Third party websites are not under our control, and we are not responsible for any third party websites, or the accuracy, sufficiency, correctness, reliability, veracity, completeness, or timeliness of their information, links, changes or updates. The inclusion or access to these websites does not imply an endorsement by JKBX, or of the provider of such content or services, or of any third party website. Please be aware that when you enter a third party website, any information you provide, including financial information, is subject to the terms of use and privacy notice of that website.
Public: We may share your information with the public if you provide such information via a public forum such as social media, chat, Discord, or other public manner.
How We Safeguard Your Personal Data
Security Systems and Processes: JKBX developed a detailed written Information Security Policy that covers all personnel, and regularly conducts company-wide training on protecting the personal information of clients and investors, as well as the disposal of non-essential customer information. We have put in place security systems designed to prevent unauthorized access to or disclosure of Personal Data, and we take all reasonable steps to secure and safeguard this Information, including:
Our Platform's password-protected section requires users to give us unique identifiers such as their user ID and password and authenticate themselves prior to accessing the Services;
We use industry standard encryption technology for any information we store;
JKBX employees are required to acknowledge that they understand the importance of protecting your Personal Data and act in accordance with company security protocols;
Where applicable, we include contractual safeguards within our agreements with companies and vendors in order to protect your Personal Data;
We provide access to our databases containing Personal Data on a need-to-know basis only; and
We use automated tools to monitor network traffic to detect, identify and track unauthorized attempts to upload information, change information, or otherwise seek to "hack into" our systems.
Our security systems are therefore structured to deter and prevent hackers and others from accessing information you provide to us. However, please understand that this information should not be construed as a warranty that our security systems are fail proof. Due to the nature of internet communications and evolving technologies, we disclaim and cannot provide assurance that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.
Other Important Privacy Information
Opting Out of Communications
If you wish to stop receiving marketing or promotional communications or to opt out of use of your information for the purposes described in this Privacy Notice, please follow the opt-out instructions, such as clicking "Unsubscribe" (or similar opt-out language), in those communications. You can also contact us here to opt out. Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to our terms of service or this notice. Please understand that you will not be allowed to opt–out of certain communications required to comply with applicable laws, rules and regulations or other legal and related notices concerning your relationship to the Platform.
Opting Out of Processing Your Data
You may request that we restrict processing your personal information, even if you have previously consented to our processing. Please contact us here. Notably opting-out of processing your data may result in our inability to provide the services you have requested.
Changing or Deleting Information
All users may review, update, correct or delete certain Personal Data that JKBX has on file by contacting us here or, in certain cases, by accessing your member account. If you request, we will take reasonable steps to remove your name and other Personal Data from our databases. Please understand, however, that:
it may be impossible to remove this information completely, due to IRS and regulatory reporting requirements, investments on the platform and the rights thereof, and data backups and records of deletions;
if you request deletion of your information, you will be unable to use certain features of the Platform and any associated Services; and
certain Personal Data may remain in our databases following the deletion of your account pursuant to our data retention policy.