Corporate Challenge Privacy Policy, effective February 25, 2022

• We obtain your Personal Data when you provide it to us.
• We collect Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), to the extent that you choose to make your profile publicly visible). 
• We may collect your Personal Data from third parties who provide it to us such as your employer or your Team Captain, in which case the third party will be responsible for making you aware of this Policy as and when appropriate.
• We collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site. When you visit a Site, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a Site and other technical communications information), some of which may constitute Personal Data.

Creation of Personal Data: We create Personal Data about you, such as records of the races you participate in, subject to applicable law.

Relevant Personal and Sensitive Personal Data: The categories of Personal Data about you that we Process, subject to applicable law, are as follows:

• Personal details: given name(s); display name; gender; date of birth / age;  government issued number(s number(s); nationality; photographs; visual images.
• Family details: names and contact details of family members and dependents.
• Contact details: address, telephone number, and email address for you and your emergency contacts.
• Employment details: industry; role; business activities; names of current and former employers; work address; work telephone number; work email address.
• Financial details: billing address; bank account numbers; credit card numbers; cardholder or accountholder name and details; instruction records; transaction details; and counterparty details.
• Views and opinions: any views and opinions that you choose to send to us, or publish about us (including on social media platforms)
• Electronic Identifying Data: IP addresses; cookies; activity logs; online identifiers; unique device identifiers; and geolocation data.

Processing your Sensitive Personal Data: We do not seek to collect or otherwise Process your Sensitive Personal Data, except where:

• the Processing is necessary for compliance with a legal obligation (e.g., to comply with our diversity reporting obligations);
• the Processing is necessary for the detection or prevention of crime (including the prevention of fraud) to the extent permitted by applicable law;
• you have manifestly made those Sensitive Personal Data public;
• the Processing is necessary for the establishment, exercise or defence of legal rights
• we have, in accordance with applicable law, obtained your explicit consent prior to Processing your Sensitive Personal Data (as above, this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way); or
• Processing is necessary for reasons of substantial public interest and occurs on the basis of an applicable law that is proportionate to the aim pursued and provides for suitable and specific measures to safeguard your fundamental rights and interests.

Purposes for which we may Process your Personal Data, and legal bases for Processing: The purposes for which we may Process Personal Data, subject to applicable law, and the legal bases on which we may perform such Processing, are as follows: 

• you and, where appropriate, your family, and emergency contact
• your team captain, your employer, and other representatives of your employer;
• Governmental, legal, regulatory, or similar authorities, ombudsmen, and central and/or local government agencies, upon request or where required, including for the purposes of reporting any actual or suspected breach of applicable law or regulation;
• accountants, auditors, financial advisors, lawyers and other outside professional advisors to J.P. Morgan, subject to binding contractual obligations of confidentiality;
• accreditation bodies and local organizers who assist J.P. Morgan with operating and managing the event, including obtaining relevant permits;
• third party Processors (such as payment services providers; shipping companies; on-site medical care teams (as applicable); etc.), located anywhere in the world, subject to the requirements noted below in this Section 3;
• any relevant party, claimant, complainant, enquirer, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights in accordance with applicable law; any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security in accordance with applicable law;
• any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation);
• the press and the media; and
• voluntary and charitable organisations.

Our Sites may use third party plugins or content. If you choose to interact with any such plugins or content, your Personal Data may be shared with the third party provider of the relevant social media platform. We recommend that you review that third party’s privacy policy before interacting with its plugins or content.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

International transfer of Personal Data 

Because of the international nature of our business, we may need to transfer your Personal Data within the J.P. Morgan group, and to third parties as noted in Section 3 above, in connection with the purposes set out in this Policy. For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements, including data protection laws of a lower standard to those that apply in the country in which you are located.

Where we transfer your Personal Data to other countries, we do so on the basis of:

• adequacy decisions;
• our Binding Corporate Rules;
• suitable Standard Contractual Clauses; or
• other valid transfer mechanisms.

If you want to receive more information about the safeguards applied to international transfers of personal data, please use the contact details provided in Section 12 below.

You are responsible for ensuring that any Personal Data that you send to us are sent securely.

• your Personal Data that we Process are accurate and, where necessary, kept up to date; and
• any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay
  

From time to time we may ask you to confirm the accuracy of you Personal Data.

• permanently delete or destroy the relevant Personal Data;
• archive your Personal Data so that it is beyond use; or
• anonymise the relevant Personal Data.

Your legal rights
Subject to applicable law, you may have a number of rights regarding the Processing of your Personal Data, including:

• the right to request access to, or copies of, your Personal Data that we Process or control, together with information regarding the nature, processing and disclosure of those Personal Data;
• the right to request rectification of any inaccuracies in your Personal Data that we Process or control;
• the right to request, on legitimate grounds:
  • erasure of your Personal Data that we Process or control; or
  • restriction of Processing of your Personal Data that we Process or control;
• the right to have your Personal Data that we Process or control transferred to another Controller, to the extent applicable;
• where we Process your Personal Data on the basis of your consent, the right to withdraw that consent; and
• the right to lodge complaints with a Data Protection Authority regarding the Processing of your Personal Data by us or on our behalf.

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided in Section 12 below.

Cookies
A cookie is a small file that is placed on your device when you visit a website (including our Sites). It records information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Data through cookie technology, in accordance with our Cookie Policy.

Direct Marketing
We may Process your Personal Data to contact you, primarily by mail and email and also on occasion by telephone, provided that we have first obtained your consent, to the extent required by, and in accordance with, applicable law.

If you do not wish to receive marketing communications from us you can opt out at any time by contacting your regular J.P. Morgan contact, or by electronically unsubscribing from emails we have sent to you. After you unsubscribe, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any services you have requested.

Contact details
If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of Personal Data by J.P. Morgan, please contact: series-info@corpchallenge.jpmorgan.com.

 Defined terms