Scope of Disclosures
This California Privacy Notice (the “CA Notice”) applies to information that JMP Group LLC and its subsidiaries, including, without limitation, Harvest Capital Credit Corporation, Harvest Capital Strategies LLC, HCAP Advisors LLC, JMP Asset Management LLC, and JMP Securities LLC collect in connection with their websites and services (each a “JMP Group Entity” and collectively, “JMP Group,” “we,” “us,” or “our”). This CA Notice supplements the information contained in each of the JMP Group Entity’s respective Privacy Notice and applies solely to individual residents of the State of California (“consumers” or “you”). Any reference to “Privacy Notice” within this CA Notice refers to the website privacy notice of each specific JMP Group Entity.
This CA Notice provide additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).
Unless otherwise expressly stated, all terms in this CA Notice have the same meaning as defined in the CCPA.
Personal Information Disclosures
When we use the term “personal information” in this CA Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
For the purposes of this Notice, personal information does not include:
- Publicly available information from government records.
- Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
- Information excluded from the CCPA’s scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
- Information relating to our job applicants.
Collection and Use of Personal Information
In the last 12 months, we have collected the following categories of personal information from the categories of sources and for the purposes set forth below, which reference the personal information, sources and purposes described in the Privacy Notice of each JMP Group Entity:
|Category of Personal Information||Collected|
|Identifiers, such as your name, address, telephone number, or other similar identifiers.|
|California Customer Records (Cal. Civ. Code § 1798.80(e)), such as social security number, signature, passport number, driver’s license or state identification card number, bank account number, tax identification number, or other financial information.|
|Protected Classification Characteristics, such as national origin and citizenship status.|
|Commercial Information, such as payment details and information about products or services purchases, obtained or considered.|
|Biometric Information, such as physiological and behavioral characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as voice prints or fingerprints.|
|Internet/Network Information, such as your browsing history, log and analytics data, search history and information regarding your interaction with our websites or services.|
|Geolocation Data, such as information about your physical location collected from geolocation features on your device, including your IP address, as well as information about your physical location collected from records of visits to our premises and CCTV recordings.|
|Sensory Information, such as pictures you provide or upload in connection with our services, and the content and audio recordings of phone calls between you and us that we record where permitted by law.|
|Profession/Employment Information, such as current and past employment or professional experience.|
|Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99), such as information about your level of education or educational history.|
|Other Personal Information, such as personal information you provide us in relation to a question, request or inquiry.|
|Inferences, including information generated from your use of our services reflecting predictions about your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.|
Sources of Personal Information
We collect personal information about you from one or more of the following sources:
- Directly from you, including via information we receive about you on applications or other forms or orally.
- Indirectly from you, such as through information we collect from you in the course of providing services to you.
- Other JMP Group Entities or affiliates.
- Service providers. For example, from custodians or broker-dealers who provide financial services to our clients or from third parties in the course of regular due diligence or background checks such as credit reporting agencies.
- Third parties you direct to share information with us.
- Your browser or device.
Please note: In addition to the categories of sources identified above, we may collect information from publicly available sources and other third-party information providers in order to supplement the information we have otherwise collected.
Purposes for Collecting Personal Information
We collect, use or disclose personal information about you for one or more of the following purposes:
- To fulfill or meet the reason the information was provided, such as: to fulfill our contractual obligations; to consider opening an account or entering into a relationship with you at your request; to deliver the services you have requested; to process transactions in your account; to respond to inquiries from you or your representative; to provide you with notifications, reports, statements, and other notices regarding your account; to manage payments, fees and charges and to collect and recover money owed to us.
- To communicate with you, including via email and/or telephone calls.
- To better understand the demographics of our visitors and measure traffic and analytics on our websites and services.
- For our internal business purposes, such as data analysis, customer research, audits, fraud prevention, developing new products and/or features, enhancing the services, and improving the services and identifying usage trends.
- To maintain the safety, security, and integrity of the services, technology assets, and business.
- To comply with legal or regulatory obligations, such as: to interact with governmental or regulatory authorities, including self-regulatory organizations; to respond to law enforcement and regulatory agency requests, as required by applicable law, court order, or governmental regulations; to detect or prevent fraud and/or other criminal activity, including performing anti-money laundering, anti-terrorism, sanction screening, fraud and other due diligence checks.
Recipients of Personal Information
We share personal information with a variety of third parties for business purposes. We disclose personal information to the following categories of third parties:
- Within JMP Group: We may disclose personal information between and among JMP Group LLC and its current and future parents, affiliates, subsidiaries, JMP Group Entities, and other companies under common control or ownership.
- Service providers: We share personal information with third-party vendors, consultants and other service providers who perform functions or services on our behalf and under our instructions to make our services available to you, subject to contractual terms restricting the collection, use and disclosure of your personal information. For example, this may include vendors and providers who engage in marketing or advertising activities or provide mailing or email services, tax and accounting services, auditing and compliance, ID verification, fraud prevention, infrastructure provisioning, analytics services, IT services, product fulfillment, and web hosting services.
- Third parties at your request: We share your personal information with third parties with whom you authorize us to disclose your personal information in connection with products and services we provide to you.
- Law enforcement and third parties pursuant to legal request: We may disclose personal information as reasonably necessary to respond to law enforcement requests and as required by applicable law, court order, or governmental entities or self-regulatory association requirements.
Your California Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):
|The Right to Know||You have the right to request any or all of the following information relating to the personal information we have collected about you or disclosed in the last 12 months, upon verification of your identity:
|The Right to Request Deletion||You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.|
|The Right to Opt Out
of Personal Information Sales
|You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future.
If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
|The Right to
|You have the right not to receive discriminatory treatment for exercising any of the rights described above.
However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.
How to Exercise Your California Privacy Rights
Please note that when you submit a request to us, that request will only be processed with respect to the specific JMP Group Entity to which you have submitted such request.
To Exercise Your Right to Know or Right to Deletion
To exercise your right to know and/or right to deletion, please submit a request by:
- Emailing email@example.com with the subject line “California Rights Request,” or call
- Click here to View Phone Number
When submitting a request, please identify the specific JMP Group Entity/Entities to whom you are making a request and describe your relationship with us and your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise the right to know and/or the right to deletion to that personal information identified in your request, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.
Minors Under Age 16
We do not sell the personal information of consumers we know to be less than 16 years of age. Please contact us at firstname.lastname@example.org to inform us if you, or your minor child, are under the age of 16.
Updates to This CA Notice
We will update this CA Notice from time to time. When we make changes to this CA Notice, we will change the “Last Updated” date at the beginning of this CA Notice. If we make material changes to this CA Notice, we will notify you by email to your registered email address, by prominent posting on our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.
If you have any questions or requests in connection with this Notice or other privacy-related matters, please send an email to email@example.com.
Alternatively, inquiries may be addressed to:
JMP Group LLC
600 Montgomery St., Suite 1100
San Francisco, CA 94111