Disclaimer
PAST PERFORMANCE IS NOT INDICATIVE OF FUTURE PERFORMANCE RESULTS. USERS OF THIS WEBSITE SHOULD BE ADVISED THAT THERE IS THE RISK OF LOSS AS WELL AS THE OPPORTUNITY FOR GAIN BY INVESTING WITH EJF CAPITAL LLC.
Terms of Use
THE WEBSITE USER SHOULD READ THESE TERMS CAREFULLY BEFORE USING THE SERVICES DESCRIBED HEREIN. BY CLICKING “ACCEPT” YOU ACKNOWLEDGE THAT YOU HAVE READ THESE TERMS AND THAT YOU AGREE TO BE BOUND BY THEM. AS A RESULT, YOU ARE AN AUTHORIZED USER (“USER”) OF THE INFORMATION LOCATED UNDER THE DOMAIN WWW.EJFCAP.COM (“WEBSITE”). IF YOU DO NOT AGREE TO ALL OF THE TERMS OF THIS AGREEMENT, YOU ARE NOT A USER AND ARE PROHIBITED FROM ACCESSING THE WEBSITE AS WELL AS VIEWING, DISSEMINATING OR USING THE INFORMATION CONTAINED THEREIN.
Modification of Terms
This Website is owned and operated by EJF Capital LLC ("EJF"). EJF reserves the right, in its sole discretion, to modify, change, add, or remove portions of these terms at any time. EJF suggests that the User of the Website periodically check these terms for modifications. Any changes, modifications, or additions to, or deletions from these terms shall be effective upon posting on this Website. If the User accesses this Website after EJF posts changes to the terms, the User accepts the terms as changed. EJF reserves the right to monitor any use of this Website. The terms can be accessed from the link at the bottom of the Website page.
Intended Audience
This information was prepared exclusively for the benefit and internal use of the party to whom EJF has provided it, and may not be published or disclosed, in whole or in part, to any other party. The information provided on the Website is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation, or which would subject EJF or its affiliates to any registration requirement within such jurisdiction or country.
Disclaimer
Nothing reflected on this Website shall constitute tax, legal, insurance, or investment advice. Neither the information, nor any opinion, contained on this Website constitutes a solicitation or offer by EJF or its affiliates to buy or sell any fund or other financial instruments, nor shall any such fund or other financial instrument be offered or sold to any User in any jurisdiction in which such offer, solicitation, purchase, or sale would be unlawful under the securities laws of such jurisdiction. Decisions based on information reflected on this Website are the sole responsibility of the User viewing the site. In exchange for the ability to use this Website, the User viewing the information on the site agrees to indemnify and hold EJF, its officers, directors, employees, affiliates, agents, licensors and suppliers harmless against any and all claims, losses, liability, costs and expenses (including but not limited to attorneys’ fees) arising from the use of this Website, from the violation of these terms or from any decisions that the User viewing the Website makes based on such information.
No Offer or Advice
This Website does not constitute an offer to sell or a solicitation of an offer to buy any fund that may be referenced on or through this Website. Nor does this Website constitute an offering or recommendation by EJF of any security, investment management service, or advisory service. EJF does not provide investment advice, tax advice, or legal advice through this Website, and the User agree that this Website will not be used by the User for such purposes. EJF does not represent that the funds, or services discussed on this Website are suitable for any particular investor. The User acknowledges that its requests for information are unsolicited, and the provision of any information through this Website shall not constitute or be considered investment advice, or an offer to buy or sell a particular fund.
Password Security
To gain access to the Website, the User must enter a User ID and password. The User may not obtain unauthorized access to such parts of the Website, or to any other protected materials or information, through any means not intentionally made available by EJF for the User’s specific use. If the User has a password to access non-public areas of the Website, the User is solely responsible for all activities that occur in connection with the User’s password. Additionally, the User should take steps to protect the confidentiality of its password. After receiving authorization from the User, EJF will provide parties such as the User’s accountant, tax professional, etc. with a different password that will allow them to view their information. The User should contact EJF immediately if it becomes aware of any disclosure, loss, theft or unauthorized use of its password.
Termination
EJF reserves the right to terminate a User’s access to the Website for any reason, without prior notice.
GOVERNING LAW
These terms will be governed and construed under the laws of the state of Delaware without regard to its conflict of law principles, regardless of whether the User resides in Delaware or transacts business with EJF in Delaware or elsewhere. Nothing in these terms creates any rights or protections that the User is not already entitled to by law. If any part of these terms is held invalid or unenforceable, that part will be deemed modified as necessary to make it effective, and the remaining provisions of these terms will remain in effect.
EJF Capital Investor Portal Privacy Policy
NOTICE OF PRIVACY POLICY
Thank you for visiting the investor portal of EJF Capital LLC and its affiliates (“EJF” or “we” or “our”). We respect your privacy and are committed to protecting it through our compliance with this policy (the “Privacy Policy”).
This Privacy Policy describes the types of information we may collect from you, or about you, or that you may provide when you visit our investor portal (https://portal.ejfcap.com/login) (the “Portal”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.
Please read this Privacy Policy carefully to understand our policies and practices regarding how we collect, use, share, and protect your information. By using the Portal, you are agreeing to the terms of this Privacy Policy, as posted here. If you do not agree with any terms or practices described in this Privacy Policy, please do not access, use or visit the Portal. This Privacy Policy may change from time to time, so please check the Privacy Policy periodically for updates (see the “Changes to Our Privacy Policy” section below).
SCOPE OF THIS PRIVACY POLICY
This Privacy Policy applies to information we collect on the Portal. It does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by EJF or any third party; or
- Us that is subject to the Gramm-Leach-Bliley Act (and its implementing regulations) or similar state laws, which is subject to a separate Privacy Notice.
INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
We collect several types of information from and about users of our Portal (collectively, “personal information”) which includes:
- Identifying information, such as your first name, last name, username or similar identifier;
- Contact information, such your email address;
- Technical information, such as information about your internet connection, the equipment you use to access our Portal, and your activities while browsing the Portal;
- Usage information, such as your browser time, the pages you view, and your location;
- Profile information, such as your username and password on the Portal; and
- Security questions and answers, for secure account recovery purposes.
We collect this information:
- Directly from you when you provide it to us.
- Automatically as you navigate through the Portal.
- From internet service providers.
- From our investment portal service provider.
- From operating systems and platforms.
INFORMATION YOU PROVIDE TO US
The information we collect on or through our Portal may include:
- Information that you provide by filling in a form on our Portal.
- We may also ask you for information if you report a problem with our Portal.
INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES
As you navigate through and interact with the Portal, we may use automatic data collection technologies to collect certain information about your equipment or devices, browsing activities, and patterns, including:
- Details of your visits to our Portal, including web traffic data, location data, clickstream data, logs, and other communication data and the resources that you access and use on the Portal.
- Information about your computer or device and internet connection. Information collected automatically may include usage details, IP addresses, browser types, operating systems, device identification numbers, and information collected through cookies and other tracking technologies.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). See the “‘Choices About How We Use and Disclose Your Information” section below for information on how you can opt out of behavioral tracking on the Portal and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
The information we collect automatically, may, under the laws of certain jurisdictions, include personal information. We may also maintain such automatically-collected information with personal information we collect in other ways or receive from third parties. It helps us to improve our Portal and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Portal according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Portal.
The technologies we use for this automatic data collection may include:
- Cookies. A cookie is a small file placed on the hard drive of your computer by websites that you visit. Cookies are widely used to make websites work, or work more efficiently, and to provide information on web browsers, such as browser type, time spent on a website, pages visited, and other traffic data. For more information on our use of cookies on the Portal and how you can opt-out of them, please see our Cookie Policy.
HOW WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Portal and their contents to you.
- To provide you with information or services that you request from us, to send you information (including email alerts and commentary) about us and in accordance with your preferences for our legitimate interests in communicating with you.
- To fulfill any other purpose for which you provide it.
- To notify you about changes to our Portal and material changes to our Privacy Policy or Terms of Use.
- To allow you to participate in interactive features on our Portal.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about our Portal users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect from you or that you provide as described in this Privacy Policy:
- To our affiliates and other members of the EJF group.
- To contractors, attorneys, banks, auditors, and other third parties we use to support our business working on our behalf for the purposes described in this Privacy Policy.
- To technology and IT service providers (such as cloud service providers and software-as-a-service providers).
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of EJF’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by EJF about our Portal users is among the assets transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply our Terms of Use.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of EJF, our clients, investors, or others.
- In accordance with our rights under applicable law.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the personal information you provide to us. We offer the following mechanisms to provide you with control over your information:
- Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may be inaccessible or not function properly.
- California Residents. California residents may have additional personal information rights and choices. Please see the section titled “Your California Privacy Rights” below for more information.
- International Residents. Residents in the European Economic Area, the United Kingdom, Switzerland, and the Cayman Islands may also have additional personal information rights and choices. Please see the section titled “Additional Information Regarding the EEA, the UK, Switzerland, and the Cayman Islands” below for more information.
YOUR CALIFORNIA PRIVACY RIGHTS
California “Do Not Track” Disclosures
California law requires us to let you know how we respond to web browser Do Not Track (“DNT”) signals. This feature lets you tell websites that you visit that you do not want to have your online activity tracked. Because there currently is not any industry or legal standard for recognizing or honoring DNT signals, we do not respond to DNT signals at this time.
California “Shine the Light” Disclosures
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Portal that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@ejfcap.com or write us at: EJF Capital LLC, 2107 Wilson Boulevard Suite 410 Arlington, VA 22201. We will respond to your request in accordance with applicable law and reserve our right not to respond to requests submitted other than to the email or mailing addresses specified in this section.
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
EJF is headquartered in the United States and has an office in theUK. . Our servers are also located in the United States. This means that personal information that you transfer to us through use of our Portal may be transferred to, stored, or processed in the United States or in other jurisdictions where our affiliates, service providers, employees, agents, contractors, consultants, professional advisers, data processors and persons employed and/or retained by them and business partners operate. Where we transfer personal information to such individuals or entities outside of the UK, the European Economic Area (“EEA”), or other territories subject to data transfer restrictions, we will ensure that our arrangements with them are governed by data transfer agreements or safeguards, designed to ensure that your personal data is protected as required under applicable data protection law (including, where appropriate, under an agreement on terms approved for this purpose by the UK Government, the European Commission or by obtaining your consent).
For more information on the safeguards applied to such transfers, please contact info@ejfcap.com.
ADDITIONAL INFORMATION REGARDING THE EEA, THE UK, SWITZERLAND, AND THE CAYMAN ISLANDS
We recognize the importance of protecting your personal data. This Privacy Policy explains how we collect, store, and use your personal data in compliance with applicable data protection law as a controller, including, where relevant (as amended from time to time), the General Data Protection Regulation (EU) 2016/679 (“EU GDPR”) and any national laws enacted pursuant to the EU GDPR, the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 No. 419 (“UK GDPR,” together with the EU GDPR, the “GDPR”), the Swiss Federal Data Protection Act (“DPA”), and the Data Protection Law, 2017 of the Cayman Islands (“DPL”). Unless we inform you otherwise, EJF Capital LLC and/or one or more of its affiliates is the data controller in respect of processing your personal data. A data controller is responsible for deciding the ways in which and purposes for which personal data about you is processed.
When used in this notice, unless otherwise stated, the terms “controller,” “processor,” “personal data,” “process,” and “processing” have the meanings given to them in the GDPR, the DPA, and the DPL, as applicable.
Categories of Personal Data
The categories of personal data that we collect from or about you are set forth in the section titled “Information We Collect About You and How We Collect It” above.
Uses of Personal Data
Your personal data may be stored and processed by us for the following purposes:
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Purpose/Activity
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Types of Data
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Lawful Basis for Processing
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To administer our business and manage our relationship with you, which will include notifying you about developments related to your actual or potential investment, changes to our Terms of Use or this Privacy Policy, and other communications of information to you, discussions with our service providers and counterparties, decision-making, business strategy, and development and marketing.
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- Identifying
- Contact
- Profile
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- Performance of a contract with you.
- Necessary to comply with a legal obligation.
- Necessary for our legitimate interests (to keep our records updated about changes to our Terms of Use and policies).
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To protect our business and the Portal (including troubleshooting, data analysis, testing, system maintenance, support, reporting, security and hosting of data).
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- Identifying
- Contact
- Usage
- Technical
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- Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or restructuring exercise).
- Necessary to comply with a legal obligation.
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To deliver relevant Portal content to you and to monitor, measure, or understand the effectiveness of the information we provide to you.
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- Identifying
- Contact
- Profile
- Usage
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Depending on whether we have an existing business relationship and where you are based, either:
- Your consent; or
- Necessary for our legitimate interests (to develop our products/services, to grow our business, and to inform our marketing strategy).
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To undertake business development and marketing activities in relation to making suggestions and recommendations to you about products or services that may be of interest to you. This may include direct electronic marketing.
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- Identifying
- Contact
- Profile
- Technical
- Usage
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Necessary for our legitimate interests in promoting products and services and growing our business.
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To investigate and address violations of our Terms of Use and policies, detect, prevent, and combat harmful or unlawful behavior, and meet any of our legal, regulatory, or risk management obligations.
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- Identifying
- Profile
- Contact
- Technical
- Usage
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- Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise).
- Necessary to comply with a legal obligation.
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Your Rights
Depending on the law of your country or region, or where the processing of your personal data occurs, you have a number of legal rights in relation to the personal data that we hold about you from the Portal.
When the processing of your personal data is governed by the GDPR, you have rights as an individual that you can exercise in relation to the information held about you under certain circumstance. These rights are to:
(a) The right to access your personal data (commonly known as a “data subject access request”). You have the right to receive a copy of your personal data and to verify that we are using your data in compliance with law.
(b) The right to ask that we transfer your personal data to you or to a third party. This right is applicable only when the use is based on performance of a contract or the consent of the person involved. You have the right to receive some personal data in a structured, commonly used and machine-readable format and the right to request that we transmit that data to a third party where this is technically feasible. Please note that this right only applies to personal data that you have provided to us.
(c) The right to request that we correct (rectify) your personal data if it is inaccurate or incomplete.
(d) The right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it.
(e) The right to request that we restrict our processing of your personal data in certain circumstances, including, but not limited to, where you contest the accuracy of such personal data. Please note that there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to continue processing your personal data or to refuse that request.
(f) The right to object to the use of your data, on grounds relating to your specific situation, where the processing of your personal data is premised on our legitimate interests or those of a third party.
(g) The right to withdraw your consent to the use of your data if the legal basis of the use is your consent.
(h) The right to lodge a complaint with a data protection regulator (the details of which are provided below) if you think that any of your rights have been infringed by us.
You can exercise your rights by contacting us using the details set out under the “Contacting Us” section below. You can find out more information about the rights you may have under the GDPR by contacting a data protection authority for your country or region, or where an alleged infringement of applicable data protection law occurs. A list of EEA data protection authorities is available at: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm. Information regarding the UK data protection authority is available at: https://ico.org.uk/. Information regarding the Ombudsman for the Cayman Islands is available at: https://ombudsman.ky/get-in-touch.
AUTOMATED DECISION-MAKING
We do not use automated processing, including profiling, to make decisions that will have either legal or material effects on the individuals from who we collect and process personal information.
CHILDREN’S PRIVACY
Use of the Portal is not intended for children under eighteen (18) years of age. We do not knowingly collect personal information from individuals under the age of 18.
SECURITY
We have implemented measures designed to secure the Portal and your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. We cannot guarantee the security of your personal information transmitted to our Portal, and we urge you to use caution on the internet. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Portal. If you have reason to believe that your interaction with the Portal is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
RETENTION
We retain personal information only for as long as the information is needed to fulfill the purposes for which it was collected and processed. We will delete, anonymize or de-identify personal information within a reasonable time after the data is no longer necessary for the business purposes for which it was collected. We will, however, retain and use personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
CHANGES TO OUR PRIVACY POLICY
It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Portal home pages. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Portal and this Privacy Policy to check for any changes.
CONTACTING US
To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:
EJF Capital LLC
2107 Wilson Boulevard
Suite 410
Arlington, VA 22201
info@ejfcap.com
703-875-9121