JHL Capital Group LLC ® (together with its affiliates and funds, "JHL") understands that visitors to its website, www.jhlcapitalgroup.com (the "Site"), are concerned about the privacy of their information. This Online Privacy Policy describes how JHL collects, uses, discloses, updates, and protects information you provide to JHL on the publicly available portions of the Site. Links to this Online Privacy Policy are available on the Site's homepage and at the bottom of each page throughout the Site. By using the Site, you expressly accept and agree to abide by the terms set forth in this Online Privacy Policy. For other information regarding the terms and conditions of viewing and using the Site please see the JHL Site Terms of Use.

This policy is in addition to the privacy policies and procedures applicable to JHL’s investors, as summarized in the privacy policy that is provided to such investors.

Personal Information
For the purpose of this Online Privacy Policy, "personal information" means information about any identifiable individual. This Online Privacy Policy only sets forth JHL's policy towards personal information collected through the Site, but does provide some details on other information collected (e.g., through cookies) solely for informational purposes.

Please note that any comments, suggestions, or materials provided to JHL shall be deemed to be of a non-confidential and non-proprietary nature (becoming the property of JHL upon JHL’s receipt of same) and JHL shall be entitled to use and distribute such comments, suggestions, or materials to any other parties and for any other purposes, including, but not limited to, developing and marketing products or services incorporating or based on any such comments, suggestions, or materials.

Personal Information Collected
The Site does not collect any personal information about you except when you knowingly provide such information. Examples of personal information JHL collects include: contact information (such as name, address, email address, and telephone number), and unique identifiers, such as account information.

JHL may collect email addresses of those of its investors that choose to access the private, restricted area of the Site reserved for JHL investors that is linked to a third-party website. At times, visitors to the Site may choose to email individuals at JHL using email addresses available on the Site; in such instances, a visitor’s email address may be collected as part of the process of sending the email to JHL in order to enable JHL to reply to those emails.

The Site may use "cookies," which may automatically collect certain information and data. "Cookies" are small pieces of data sent to your computer browser from JHL's web server and stored on your computer's hard drive so the Site can recognize you as you browse between web pages on the Site. JHL may use cookies to deliver content specific to your interests, to save your information so you don't have to re-enter it each time you visit the Site, to determine the type of information that you are looking for on the Site, to improve the Site, to help JHL diagnose problems with JHL's server, and for other purposes. JHL also may use information about the website you visited immediately prior to the Site to assess the viability of links to the Site that JHL has created on third-party websites. Cookies do not provide JHL with any information about your name, address, phone number, or email address, or any other personally identifiable information. JHL may, however, log visitor IP addresses. If you do not wish to have a cookie sent to your browser, you can change the settings on your internet browser to stop it from automatically accepting cookies. While rejecting a cookie will not normally affect your browsing or your ability to access the features on the Site, you may find that certain navigational elements of the Site have limited functionality.

Use of Personal Information
JHL may use your personal information for the following purposes:

  • to develop and maintain JHL’s relationship with you and otherwise contact you when necessary;
  • to develop and improve JHL’s services and websites;
  • to help diagnose problems with JHL’s servers, and to administer the Site;
  • to assist law enforcement agencies, to collect outstanding debts, to protect JHL’s business interests and the interests of JHL’s investors, and to generally meet requirements imposed by law based on JHL’s good faith belief of what is necessary to meet the requirements imposed by law; and
  • to prevent fraud and to otherwise, in good faith, protect the users of the Site or the public in general.

The personal information you provide to JHL when applying for a position (e.g., resume, standardized test scores, etc.) will be processed by JHL and its vendors exclusively for recruiting and employment purposes (recording, examination, assessment, selection, conclusion of an employment offer, storage in JHL's recruitment database for a possible future offer of employment, etc.). Except to the extent necessary in connection with accommodations requested as part of the application or employment process, please do not provide sensitive data, as may be defined by your country's laws (e.g., personal information regarding sexual orientation, race, ethnic origin, religion, health, or disability).

By sending your personal information to apply for a position at JHL, you give your consent to the processing of your personal information in the above manner. In addition, you affirm that all information contained within your submission is accurate and that you have the right to provide JHL with any and all information that you submit.

Disclosure of Personal Information
JHL may disclose personal information to its affiliates and agents and to third-party vendors and other parties engaged to assist JHL in providing products or services to you or to carry out one or more of the purposes described above. In general, JHL’s business practices limit access to personal information obtained through your use of the Site to those personnel who need to know such information to conduct JHL’s operations.

JHL reserves the right to cooperate fully with local, state, and federal officials in any investigation relating to any personal information (including private electronic communications transmitted on the Site or any other website owned or operated by JHL) or any purportedly unlawful activities.

Data and Network Security
JHL maintains commercially reasonable operational policies, including physical, electronic, and procedural protections to safeguard and secure its data networks to prevent the unauthorized access to data JHL may collect online.

Criminals use various techniques to gather your personal information for use in identity theft, credit fraud and other illegal activities. These attempts may be sophisticated in nature and designed to appear that they are requests from companies with which you may have a legitimate relationship. Do not provide your personal information to a third party unless you are certain of that party’s identity. If you are concerned that a third party is trying to obtain your information by impersonating JHL, please contact JHL at JHL Capital Group LLC, Attn: General Counsel, 900 North Michigan Avenue, Suite 1700, Chicago, IL 60611.

Links to Third-Party Websites
The Site may offer links to other websites. In addition, you may have visited the Site through a link or a banner advertisement on another website. In such cases, the website you linked from or link to may collect information from people who click on the banner or link. JHL is not responsible for the privacy practices employed by any other website. JHL makes no guarantees, representations, or warranties as to the privacy practices of any other website, including websites that may be reached by links in the Site. After leaving the Site, whether via a link contained on the Site or through the use of your web browser or some other navigational tool, this Online Privacy Policy is no longer in effect. It is important to familiarize yourself with the privacy policies of other websites before providing them with your personal information.

Changes to this Online Privacy Policy
JHL may revise and update this Online Privacy Policy from time to time without additional notice to you. Please review the most recent version of the Online Privacy Policy by clicking on any "Privacy Policy" link on the Site. The Online Privacy Policy posted at any time or from time to time via the Site shall be deemed to be the Online Privacy Policy then in effect. By continuing to use the Site following the posting of changes, you expressly accept and agree to abide by the terms set forth in the amended Online Privacy Policy.

Access to Personal Information and Withdrawal of Consent
You may contact JHL at JHL Capital Group LLC, Attn: General Counsel, 900 North Michigan Avenue, Suite 1700, Chicago, IL 60611 to request access to or correction or update of your personal information.

You may request to no longer receive future communications from JHL, and you may withdraw consent to JHL’s collection and retention of your personal information at any time, subject to legal or contractual restrictions and reasonable notice. If you wish to withdraw your consent, please contact JHL at JHL Capital Group LLC, Attn: General Counsel, 900 North Michigan Avenue, Suite 1700, Chicago, IL 60611. JHL will inform you of the implications of withdrawing consent.

Comments
If you have any questions or comments about this Online Privacy Policy, please feel free to contact JHL at the address below:
JHL Capital Group LLC
Attn: General Counsel
900 North Michigan Avenue
Suite 1700
Chicago, IL 60611