Privacy Notice
(EMEA & APAC)
E F F EC T I V E F R O M 1 J U N E 2 0 26
WHO IS THIS NOTICE ISSUED BY AND WHAT INFORMATION DOES IT PROVIDE?
The purpose of this notice is to explain how we “process” or use your personal data, to help you understand why we
collect, use, store, share, and secure your data, and to explain your privacy rights.
This notice is issued by JPMorgan Chase & Co. and its branches, subsidiaries and affi
liates identifi
ed as the parties
responsible for determining the means and the purposes of processing your personal data, listed in Schedule A (you can
access this section by clicking
here
if you are viewing the document electronically). In this notice, we use “
J.P. Morgan
”
“
we
”, “
us
” or “
our
” depending on context. The purposes for which we may process your personal data and the legal
bases for processing (as applicable) are listed in Schedule B (you can access this section by clicking
here
if you are
viewing the document electronically).
This notice uses certain defi
ned terms:
•
A “
controller
” is a term used in certain jurisdictions and, where applicable, refers to an entity that decides how and
why personal data is processed and is usually responsible for complying with applicable data protection laws.
•
“
Personal data
” is information that is about any individual, or from which any individual is identifi
able. It can be
anything from your name to your IP address. You can see what personal data we collect in section ‘What Personal
Data do we collect, generate and use?’ or, by clicking
here
if viewing this document electronically.
•
“
Process, processed or processing
” encompasses the collection, use, storage and analysis of data. The principle
covers anything that is done with any personal data, whether or not by automated means.
This notice is designed to supplement any specifi
c terms and conditions which may be applicable to your relationship
with us. Other privacy notices, such as our
global privacy policy
, may also apply to you depending on your circumstances.
If you have any questions about the role of this document and how it applies to your personal data, please speak to your
J.P. Morgan representative.
WHO SHOULD READ THIS NOTICE?
This notice is addressed to people with whom we interact. This includes:
•
visitors to our websites (our “
Sites
”);
•
customers (including prospective customers, our customers’ advisors, family office staf
f or other associated);
•
professional advisors or consultants;
•
people connected with the account holder as professional advisors, consultants, family office staf
f, directors, interns,
secondees or officer
s;
•
representatives of an account holder (such as holders of a power of attorney or other appointed third parties);
•
vendors;
•
anyone who calls our services centers or who writes to us via post, email or social media,
•
third parties whose personal data is provided to us; and
•
other recipients of our services (together, “
you
”).
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PRIVACY NOTICE - EMEA & APAC - 2026-06
HOW WILL WE UPDATE THIS NOTICE?
This notice may be amended and updated from time to time to reflec
t changes such as the categories of data that we collect,
process and share or to reflec
t any changes in applicable law. We encourage you to regularly check this page, and we will include
the effectiv
e date in order to help you check whether or not there have been any changes since you last accessed the notice.
WHAT SHOULD I DO IF I HAVE ANY QUESTIONS?
If you have any comments, questions or concerns that are not addressed in this notice, you can contact your regular
J.P. Morgan client service contact, or the following central contacts:
•
EMEA: You can contact our Data Protection Officer at EMEA.Privacy.Ofce@jpmchase.com or via post at JPMC EMEA
Privacy, JPMorgan Chase Bank, National Association, 18th Floor, 25 Bank Street, Canary Wharf, London E14 5JP, UK.
•
Switzerland: WM.Switzerland.Privacy.Controls@jpmorgan.com or via post at 35 Rue du Rhône, 1204 Geneva, Switzerland.
•
APAC: WM.Asia.Privacy.Ofce@jpmorgan.com or via post at 22nd Floor, Charter House, 8 Connaught Road Central,
Hong Kong or 88 Market Street, 30th Floor, Capita Spring, Singapore 048948.
•
Latin America and Global Families Group: GFG.LATAM.GDPR.Inbox@jpmorgan.com or via post at 390 Madison
Avenue, Floor 30, New York, NY 10017.
OUR APPROACH TO DATA PROTECTION
Data Security
: we have implemented appropriate technical and organizational security measures designed to protect
your personal data. We protect your data in line with our global security program built on our core principles of only
using the data required for the processing in question, controlling access to systems and datasets to those who need to
use the data, and using an encryption and anonymization process to secure the data that we hold in our systems.
You are responsible for ensuring that any personal data that you send to us are sent securely.
Data Accuracy
: we take reasonable steps designed to ensure that any personal data that we process are accurate and,
where necessary, kept up to date and that any of your personal data that we process that is inaccurate (having regard to
the purposes for which they are processed) are erased or rectifi
ed without delay.
From time to time we may ask you to confi
rm the accuracy of your personal data.
Data Minimisation
: we take reasonable steps designed to ensure that your personal data that we process are limited to
the personal data reasonably required in connection with the purposes set out in this notice.
HOW DO WE COLLECT PERSONAL DATA?
We collect personal data in a number of differen
t ways. This table sets out the methods by which we collect your
personal data, with some examples.
HOW WE COLLECT PERSONAL DATA
EXAMPLES
When you provide us with personal data
•
When you fill out an account opening form.
•
When you communicate with us via email (or any other electronic channels), phone
call or letter.
•
If another party to your account provides us with personal data.
•
If you contact us, make a complaint or provide feedback, including any data that you
share with us or that we receive as a part of our investigation into your complaint or
feedback.
When you use our services
•
Transactions on your account, such as requesting a credit facility.
Search, social media and publicly available data sources
•
Public social media profiles, such as LinkedIn or Bloomberg.
•
Search engine results and news reports from available sources including Google,
Bloomberg and the Financial Times.
•
Any public entry on electoral registers, company registers or local equivalents.
From third parties who provide it to us
•
If we engage third parties such as vendor(s) to provide data to us, for example, in
connection with the services we provide to you and/or to conduct client research.
•
If we carry out any checks via credit reference agencies.
•
If we request confirmation of your employment from your employer.
•
If you purchase any of our products and services from a third party.
•
Government and law enforcement authorities.
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PRIVACY NOTICE - EMEA & APAC - 2026-06
•
If you give us your details in order to set up an online account with us.
•
When visiting 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).
HOW WE COLLECT PERSONAL DATA
EXAMPLES
When you visit or use any of our Sites
Although your provision of personal information to us in connection with some of the purposes set out in this notice
is voluntary (unless we inform you otherwise), we may be unable to provide you with our products/services (or any
part thereof) or comply with any applicable laws or regulations or guidelines and codes issued by regulatory or other
authorities if you do not do so.
HOW DOES THIS NOTICE APPLY TO THIRD PARTY PERSONAL DATA?
If you transfer third party personal data to us this notice will also apply to that personal data.
If you supply us with the personal data of third parties, you will be responsible for informing those third parties
that their personal data has been transferred to us and for informing them that this notice will apply. You are also
responsible for the collection and recording of their consent, if necessary.
In addition, if such personal data is considered as confiden
tial under applicable law, you are responsible for ensuring
that the third parties have waived any applicable confidentialit
y requirements.
WHEN DO WE RECORD OUR INTERACTIONS WITH YOU?
In some circumstances, and as permitted by applicable law, we will record, monitor and retain communications
(including facsimile, telephone conversations, email, instant messaging, your interaction with our Sites and any other
electronic communications) including those held between you and/or your agent and employees of J.P. Morgan. These
records and recordings are made for the purposes of ensuring compliance with J.P. Morgan’s legal and regulatory
obligations and internal policies. We may also transcribe and/or summarise our telephone conversations with you.
All such records will be the sole property of J.P. Morgan and will be accepted by you as conclusive evidence of the
orders, instructions or conversations recorded, if applicable.
In connection with the records held in relation to investment services and activities relating to the reception,
transmission and execution of orders, a copy of the recording of our conversations and communications with you will
be available to you and/or any competent supervisory authority, upon request, for a period specifi
ed by applicable law,
which may vary depending on your jurisdiction.
WHAT PERSONAL DATA DO WE COLLECT, GENERATE AND USE?
This table sets out the categories of personal data that we collect, generate and use. The type and amount of data that
we collect, generate, and use will diff
er depending on your relationship with us, and the services that we provide to you.
PERSONAL DATA COLLECTED, GENERATED
AND USED
EXAMPLES
Personal details
Contact details
•
Your address, telephone number, email address, and social media details.
•
Your name, including any previous names, preferred names or nicknames.
•
Your gender, date of birth, nationality and marital status.
•
Information concerning your identity, such as government issued tax identification
numbers.
•
Information about your lifestyle and social circumstances and details of your
education and qualifications.
•
Authentication data, such as your login details.
•
Photographs and visual images, such as CCTV footage if you visit our offices or
images of identity documents obtained during onboarding.
•
Information relating to your behavior, such as how you interact with our services.
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PRIVACY NOTICE - EMEA & APAC - 2026-06
PERSONAL DATA COLLECTED, GENERATED
AND USED
EXAMPLES
Employment details
•
The nature of your industry and current role, plus any other business activities.
•
The names of your current and former employers.
•
Any contact details relating to your work.
•
Your salary, remuneration and shareholdings (if any).
Financial details
•
Your billing address and bank account numbers.
•
Your instruction records, transaction details, and counterparty details.
•
Your total assets and overall financial position.
•
The fact that you have a banking relationship with J.P. Morgan Private Bank.
Views and opinions
•
Any views and opinions that you choose to send to us or make public.
•
Any views and opinions about us that you choose to send to us or make public.
Electronic Identifying Data
•
IP addresses, geolocation data, online identifiers (including in relation to your device)
and cookies.
•
Data relating to your use of our Sites, such as browsing activity or transaction logs.
Personal data of third parties
•
Any of the above in relation to other parties such as family members, dependants,
friends, employees and advisors.
Others
•
Any other personal data we receive from you (or on your behalf)
•
Any voice recordings or files (e.g. documents, audio files or video files) including
those received from you (or on your behalf) via electronic communication channels.
If we collect personal data relating to your race or ethnicity, political opinions, religious or philosophical beliefs, trade
union membership, physical or mental health, sexual life, any criminal offenc
es, genetic or biometric data or any other
information that may be deemed to be sensitive under applicable law, we will only process this data for specifi
c purposes.
The table below sets out some examples of when we might process sensitive personal data.
SENSITIVE PERSONAL DATA COLLECTED,
GENERATED AND USED
EXAMPLES
Race or ethnicity
We may request this information from you when you apply for one of our services, and
subsequently process this information for the purposes of a legal obligation, e.g. diversity
reporting.
Political opinions and religious or philosophical beliefs
You may agree to share your beliefs with us or make them public. Alternatively, we may
become aware of them during the administration of your account when we carry out
checks required for the detection and prevention of crime, or if necessary for the
establishment, exercise or defence of legal rights.
Criminal offences
We may become aware of criminal history during our financial crime checks, such as
anti-fraud procedures and anti-money laundering checks, including information received
from public sources. We will process this data in connection with our legal obligations and
for the detection and prevention of crime.
Health information
You may tell us your health information in order to ensure that you can use our services,
such as any dietary requirements that you may have. We may also request this information
from you when required by law or if it is in our legitimate interest to provide a safe and
secure environment at our premises .
Biometric data
We may request this information from you when you apply for or login to one of our
services or, we need to carry out checks such as Know Your Client checks, and for detection
and prevention of crime.
Sensitive personal data of third parties
Any of the above in relation to other parties such as family members, dependants, friends,
employees and advisors.
WHEN DO WE SHARE PERSONAL DATA WITH THIRD PARTIES?
We will share your personal data in some circumstances, such as with other members of the J.P. Morgan group and third-
party service providers who act on our instructions under legal agreements to assist us in providing our products and
services. We may also share your data with some third parties which process it in their own right and in accordance with
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PRIVACY NOTICE - EMEA & APAC - 2026-06
their own privacy policies. Examples of third-party companies include service providers for electronic signatures, or to
process votes in connection with any securities that you may hold with us. You should be aware that once your data is
shared with third parties they may also be under a legal or regulatory duty to share that information, in some cases by
making that data public, in certain jurisdictions.
WHO WE SHARE YOUR DATA WITH
EXAMPLES
Other entities within the J.P. Morgan group
Your representatives and associates, including other
parties who hold roles in relation to the same account
relationship
Third party service providers who provide services to
us, including their sub-contractors or delegates
J.P. Morgan’s professional advisors
•
We may share personal data with our accountants, auditors, financial advisors,
lawyers and other outside professional advisors.
Third party plug-in providers
Any relevant third party acquirer(s)
•
If we sell or transfer all or a portion of our business or assets.
•
If we reorganise, dissolve or liquidate all or a portion of our business or assets.
Governmental, legal, regulatory, or similar authorities
Other third parties
•
We may share your personal data for our internal operational purposes, for example
in connection with our anti-money laundering obligations.
•
We may share your personal data that we processed for the purposes of Know Your
Client checks if you wish to purchase products and services from another J.P. Morgan
company.
•
In limited circumstances and subject to appropriate controls, we may share your
personal data with our affiliates in order to assess whether or not some of their
products and services are suitable for you or to market products and services to you.
•
If another individual has authority over your account, we may disclose your personal
data to them in order to operate your account.
•
If you supply us with personal data relating to a member of your family, we may have
to share that personal data with account authorities where we need to do so in order
to meet our legal obligations and/or operate your account.
•
We may share your personal data with payment services providers, where we need to
do so in order to satisfy a payment request that you make.
•
If we hold your assets in custody as part of the services that we provide, we may
share your data with third party companies who support the market infrastructure.
•
We may share your personal data with data aggregation services if you choose to use
them, or if it is in our legitimate interests to do so.
•
We may share information with fund administrators or other service providers in
order to assist them in complying with their legal obligations, such as Know Your
Client checks.
•
We may share your personal information with relevant communication or social
media channel providers or platform hosting service providers if you choose to use
them, or if it is in our legitimate interest to do so.
•
Debt-collection agencies and tracing agencies.
•
Credit reference agencies.
•
Anti-fraud services.
•
Our Sites may use third party plug-ins or content. If you choose to interact with any
such plugins or content, your personal data will 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 such plug-ins or content.
•
If they require us to share your personal data.
•
If we are required to report any actual or suspected breach of applicable law or
regulation.
•
Any relevant party to the extent necessary for the establishment, exercise or defence
of legal rights.
•
Any relevant party for the purposes of prevention, investigation, detection or
prosecution of criminal offences or the execution of criminal penalties.
•
Any relevant party to the extent necessary for the establishment, exercise or defence
of legal rights.
•
Any relevant party for the purposes of prevention, investigation, detection or
prosecution of criminal offences or the execution of criminal penalties.
•
Any relevant party in connection with bookbuilding activities , e.g. processing your
subscription for debt securities.
•
Where you have provided your consent for social engagement or networking
purposes, introducing you to other individuals who have a relationship with
J.P. Morgan and disclosing your contact details to them.
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PRIVACY NOTICE - EMEA & APAC - 2026-06
SHARING YOUR PERSONAL DATA INTERNATIONALLY
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, in connection with the purposes set out in this notice. For this reason, we may transfer your
personal data to other countries that may have differen
t 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 will only do so in accordance with applicable law and on
the basis of:
•
adequacy decisions;
•
our Binding Corporate Rules;
•
contract or any other legally binding instruments such as suitable Standard Contractual Clauses; or
•
other valid transfer mechanisms.
If you want to receive more information about international transfers of personal data, including the safeguards applied
and countries to which your data may be transferred, please contact us using the details provided in ‘What should I do if
I have questions?’ or by clicking
here
, if you are viewing this document electronically.
HOW LONG DO WE RETAIN YOUR DATA FOR?
We will retain your personal data in line with our data retention policy and for the minimum period required. The
duration of the retention period is determined by a number of criteria including the nature of our relationship with you,
the relevant jurisdiction, the type of data and the products and services that the data relates to.
We will retain your personal data for as long as we have an ongoing relationship with you – for example, if you are a
client, or a recipient of one of our mailing lists – or where we need to retain the personal data in connection with the
purposes set out in this notice and we are permitted to do so under applicable law. In the event of a legal claim, we may
continue to process your personal data for such period as is necessary in connection with that legal claim.
After this period, we will typically retain your personal data for any additional limitation period (i.e. any period during
which a legal claim could be raised) plus two months after the end of the limitation period, in order to ensure that the
data can be used in connection with any legal claim which may be brought. During the legal hold period we will restrict
our processing of your personal data to the storage of, and maintaining the security of, the data, except to the extent
that the data needs to be reviewed in connection with any legal claim, or any obligation under applicable law.
YOUR LEGAL RIGHTS
Subject to and to the extent provided under applicable law, you may have certain rights in relation to your data and we
want to make sure that you can exercise them. In some cases, however, we may not be able to continue to provide you
with certain products and services or continue to operate your account.
To exercise one or more of these rights, or to ask a question, please contact us.
YOUR RIGHTS
DESCRIPTION
Access
You have the right to request:
•
access to or copies of, the personal data that we process or control, together with
information regarding the nature, processing and disclosures of that personal data;
To do so, you should submit a Subject Access Request by contacting us.
Rectification
If you believe that the personal data that we process or control is incomplete or inaccurate,
you have the right to request rectification.
If you believe that the personal data is inaccurate, you have the right to ask us to restrict its
processing while it is being verified.
Erasure
You have the right to request that we delete your personal data if:
•
we no longer need the personal data for the purposes for which it was processed or
collected;
•
we originally requested your consent to process the personal data, but you wish to
withdraw your consent; or
•
we are not processing your personal data lawfully, in which case you may request that
processing is restricted instead.
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PRIVACY NOTICE - EMEA & APAC - 2026-06
YOUR RIGHTS
DESCRIPTION
Restriction
You have the right to request that we restrict the processing of your personal data as
mentioned above, or alternatively if we no longer need the personal data for the original
purpose but you require the personal data for the establishment, exercise or defence of
legal claims.
Portability
Under some circumstances, you have the right to receive your personal data in a readable
format.
You may also, under certain circumstances, request that we send your personal data in a
readable format to a third party; note that we will not be responsible for how that third
party processes your personal data and you should ensure that you are comfortable with
the contractual terms or privacy arrangements that they have in place.
Objection
You have the right to object, on grounds relating to your particular situation, to the
processing of your personal data by us or on our behalf.
Consent
If we have asked for your consent in order to process your personal data, you have the
right to withdraw that consent.
Automated Processing
You have the right to request information about the existence of and an explanation of the
logic involved in, the significance of and any envisaged consequences of, any automated
processing of your personal data that has a legal effect or a significant effect on you.
You also have the right to object to automated processing, which may result in us ceasing
to carry out that processing. In certain circumstances you also have the right not to be
subject to a decision based solely on automated processing.
Complaints
You have the right to complain with us and/or to the appropriate Data Protection Authority
regarding the processing of your personal data, either by us or on our behalf.
HOW DO WE USE COOKIES ON OUR SITES?
A cookie is a small fi
le 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.
https://www.jpmorgan.com/global/cookies
We will analyse the cookie data collected by us to improve the Website and our services to you. The data collected will be
stored in our systems and protected with the same degree of security used for all other client information.
DIRECT MARKETING
We may process your personal data to contact you, primarily by mail and email (and other electronic communication
channels) and also on occasion by telephone, so that we can provide you with information concerning products and
services that may be of interest.
If you do not wish to receive marketing communications from us you can opt out at any time by informing 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 messages, but we may continue to contact you to the extent necessary for the
purposes of any services you have requested.
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PRIVACY NOTICE - EMEA & APAC - 2026-06
SCHEDULE A – JPMORGAN CHASE & CO. ENTITIES
For the purposes of this notice, the relevant JPMorgan Chase & Co. entities (which may be considered “controllers” under
the laws of certain jurisdictions) are:
JPMORGAN CHASE & CO. ENTITY
CONTACT DETAILS
J.P. Morgan SE
Taunustor 1 (TaunusTurm), 60310 Frankfurt am Main, Germany
J.P. Morgan SE - Paris Branch
Succursale de Paris - 14, place Vendôme 75001 Paris, France
J.P. Morgan SE – Luxembourg Branch
6 route de Trèves, L-2633 Senningerberg, Luxembourg
J.P. Morgan SE – London Branch
25 Bank Street, Canary Wharf, London E14 5JP, United Kingdom
J.P. Morgan SE – Brussels Branch
1 Boulevard du Roi Albert II, 1210 Brussels, Belgium
J.P. Morgan SE, Sucursal en España
Paseo de la Castellana nº 31 - 28046 Madrid, España
J.P. Morgan SE – Milan Branch
Via Catena 4, 20121 Milano, Italia
J.P. Morgan SE – Stockholm Bankfilial
Hamngatan 15, 11147 Stockholm, Sweden
J.P. Morgan SE – Amsterdam Branch
WTC Tower B 11th floor Strawinskylaan 1135,1077 XX Amsterdam, The Netherlands
J.P. Morgan SE – Copenhagen Branch, filial af
J.P. Morgan SE, Tyskland
Nicolai Eigtveds Gade 8, DK-1402 Copenhagen K, Denmark
J.P. Morgan SE - Athens Branch
266 Kifissias Avenue, 15232, Athens, Greece
J.P. Morgan (Suisse) SA
35 Rue du Rhône, 1204 Geneva, Switzerland
JPMorgan Chase Bank, N.A., Hong Kong Branch
27th Floor, Chater House, 8 Connaught Road Central, Hong Kong
JPMorgan Chase Bank, N.A., Singapore Branch
88 Market Street, 30th Floor, Capita Spring, Singapore 048948
JPMorgan Chase Bank NA
270 Park Avenue, New York, NY 10017, USA
JPMorgan Securities LLC
383 Madison Avenue, New York, NY 10179, USA
J.P. Morgan Trust Company (Singapore) Pte. Ltd.
88 Market Street, 30th Floor, Capita Spring, Singapore 048948
J.P. Morgan Trust Company (Jersey) Limited
4th Floor, Ensign House, 29 Seaton Place, St Helier, Jersey JE2 3QL
J.P. Morgan Israel LTD
46 Rothschild Boulevard, Alrov Tower, Tel Aviv, Israel 66883
JPMorgan Chase Bank, N.A., Dubai Branch
ICD Brookfield Place, Level 25, Dubai International Financial Centre, PO Box 506551,
Dubai, United Arab Emirates
JPMorgan Chase Bank, N.A., Sydney Branch
85 Castlereagh Street, Sydney NSW 2000 Australia
If you are unsure as to which JPMorgan Chase & Co. entity is collecting or processing your personal data (or, under
the laws of certain jurisdictions, the “controllers” of your personal data), please contact us using the details provided
in section ‘What should I do if I have questions?’ or by clicking the following
link
if you are viewing this document
electronically.
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PRIVACY NOTICE - EMEA & APAC - 2026-06
SCHEDULE B - PURPOSES FOR WHICH WE MAY PROCESS YOUR PERSONAL DATA, AND LEGAL BASES FOR
PROCESSING
The purposes for which we may process personal data and the legal bases on which we may perform such processing
are as follows:
PROCESSING PURPOSE
LEGAL BASIS FOR PROCESSING
Anti-Money Laundering / Know Your Client checks:
fulfilling our regulatory compliance obligations, including
‘KYC’ checks; and confirming and verifying your identity
(including by using credit reference agencies); and
screening against government, supranational bodies
(including but not limited to the European Union and the
United Nations Security Council) and/or law enforcement
agency sanctions lists as well as internal sanctions lists
and other legal restrictions.
•
The processing is necessary for
compliance with a legal obligation
; or
•
The processing is
necessary in connection with any contract
that you may enter
into with us, or to take steps prior to entering into a contract with us; or
•
We have a
legitimate interest
in carrying out the processing for the purposes of
preventing money laundering, sanctions violations and protecting against fraud (to
the extent that such legitimate interest is not overridden by your interests or
fundamental rights and freedoms); or
•
We have obtained
your prior consent
to the processing (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).
Client on-boarding:
on-boarding new clients; and
compliance with our internal compliance requirements,
policies and procedures. Information required to open and
administer accounts includes, without limitation, the
ultimate beneficial ownership, personal identification
details or, for legal entities, the LEI Code, country of
incorporation/citizenship, residence, registered address or
address of record, documentation requested by us for the
purposes of conducting Know Your Client and anti-money
laundering and counter terrorism financing identification
and verification and any information relating to tax status.
•
The processing is necessary for
compliance with a legal obligation
; or
•
The processing is
necessary in connection with any contract
that you may enter
into with us, or to take steps prior to entering into a contract with us; or
•
We have a
legitimate interest
in carrying out the processing for the purpose of
on-boarding new clients (to the extent that such legitimate interest is not
overridden by your interests or fundamental rights and freedoms); or
•
We have obtained
your prior consent
to the processing (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).
•
The processing is necessary for
compliance with a legal obligation
; or
•
The processing is
necessary in connection with any contract
that you may enter
into with us, or to take steps prior to entering into a contract with us; or
•
We have a
legitimate interest
in carrying out the processing for the purpose of
conducting financial due diligence (to the extent that such legitimate interest is not
overridden by your interests or fundamental rights and freedoms); or
•
We have obtained
your prior consent
to the processing (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).
Credit worthiness:
conducting credit reference checks
and other financial due diligence.
Provision of products and services to you:
administering
relationships and related services, including attendance at
events and granting you direct access to investment
research; performance of tasks necessary for the
provision of the requested services; communicating with
you in relation to those services.
•
The processing is necessary for
compliance with a legal obligation
; or
•
The processing is
necessary in connection with any contract
that you may enter
into with us, or to take steps prior to entering into a contract with us; or
•
We have a
legitimate interest
in carrying out the processing for the purpose of
providing products and services to you (to the extent that such legitimate interest is
not overridden by your interests or fundamental rights and freedoms); or
•
We have obtained
your prior consent
to the processing (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).
Marketing / Prospecting:
evaluating whether or not the
products and services of any of our Affiliates (or other J.P.
Morgan clients) may be of interest to you and providing
you with marketing information concerning such products
and services, by mail, e-mail, SMS, social media, post,
telephone or in person, unless you have specifically
instructed us not to do so, and subject to ensuring that
such communications are provided to you in compliance
with applicable law; maintaining and updating your
contact information where appropriate; and
communicating with other current or potential clients,
including by disclosing to them the fact that J.P. Morgan
provides services to you.
•
We have a
legitimate interest
in carrying out the processing for the purpose of
conducting marketing and prospecting (to the extent that such legitimate interest is
not overridden by your interests or fundamental rights and freedoms); or
•
We have obtained
your prior consent
to the processing (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).
10
PRIVACY NOTICE - EMEA & APAC - 2026-06
PROCESSING PURPOSE
LEGAL BASIS FOR PROCESSING
Operation of our Sites:
operation and management of our
Sites; providing content to you; displaying advertising and
other information to you; and communicating and
interacting with you via our Sites.
•
The processing is
necessary in connection with any contract
that you may enter
into with us, or to take steps prior to entering into a contract with us; or
•
We have a
legitimate interest
in carrying out the processing for the purpose of
operating our Sites (to the extent that such legitimate interest is not overridden by
your interests or fundamental rights and freedoms); or
•
We have obtained
your prior consent
to the processing (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).
•
The processing is necessary for
compliance with a legal obligation
; or
•
The processing is
necessary in connection with any contract
that you may enter
into with us, or to take steps prior to entering into a contract with us; or
•
We have a
legitimate interest
in carrying out the processing for the purpose of
managing and operating our IT systems and ensuring the security of those systems
(to the extent that such legitimate interest is not overridden by your interests or
fundamental rights and freedoms).
•
The processing is necessary for
compliance with a legal obligation
; or
•
We have a
legitimate interest
in carrying out the processing for the purpose of
providing a safe and secure environment at our premises (to the extent that such
legitimate interest is not overridden by your interests or fundamental rights and
freedoms); or
•
The processing is necessary to protect the vital interests of any individual.
•
The processing is
necessary in connection with any contract
that you may enter
into with us, or to take steps prior to entering into a contract with us; or
•
We have a
legitimate interest
in carrying out the processing for the purpose of
managing and operating the financial affairs of our business (to the extent that
such legitimate interest is not overridden by your interests or fundamental rights
and freedoms); or
•
We have obtained
your prior consent
to the processing (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).
IT operations:
management of our communications
systems; operation of IT security; and IT security audits.
Health and safety:
health and safety assessments and
record keeping; and compliance with related legal
obligations.
Financial management:
sales; finance; corporate audit;
and vendor management.
Research:
conducting market or customer satisfaction
research; and engaging with you for the purposes of
obtaining your views on our products and services.
•
We have a
legitimate interest
in carrying out the processing for the purpose of
conducting research and producing analysis (to the extent that such legitimate
interest is not overridden by your interests or fundamental rights and freedoms); or
•
We have obtained
your prior consent
to the processing (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).
Security:
physical security of our premises (including
•
The processing is necessary for
compliance with a legal obligation
; or
records of visits to our premises and CCTV recordings);
•
We have a
legitimate interest
in carrying out the processing for the purpose of
and electronic security (including login records and access
ensuring the physical and electronic security of our business, premises, and assets
details, where you access our electronic systems).
(to the extent that such legitimate interest is not overridden by your interests or
fundamental rights and freedoms).
•
The processing is necessary for
compliance with a legal obligation
; or
•
We have a
legitimate interest
in carrying out the processing for the purpose of
detecting, and protecting against, breaches of our policies and applicable laws (to
the extent that such legitimate interest is not overridden by your interests or
fundamental rights and freedoms).
•
The processing is necessary for
compliance with a legal obligation
; or
•
We have a
legitimate interest
in carrying out the processing for the purpose of
establishing, exercising or defending our legal rights (to the extent that such
legitimate interest is not overridden by your interests or fundamental rights and
freedoms).
Investigations:
detecting, investigating and preventing
breaches of policy, and criminal offences, in accordance
with applicable law.
Legal compliance:
compliance with our legal and
regulatory obligations under applicable law.
•
The processing is necessary for
compliance with a legal obligation
.
Legal proceedings:
establishing, exercising and defending
legal rights.
11
PROCESSING PURPOSE
LEGAL BASIS FOR PROCESSING
Improving our products and services:
identifying issues
with existing products and services; planning
improvements to existing products and services; and
creating new products and services.
•
The processing is
necessary in connection with any contract
that you may enter
into with us, or to take steps prior to entering into a contract with us; or
•
We have a
legitimate interest
in carrying out the processing for the purpose of
improving our products or services (to the extent that such legitimate interest is
not overridden by your interests or fundamental rights and freedoms); or
•
We have obtained
your prior consent
to the processing (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).
Risk Management:
Audit, compliance, controls and other
risk management.
•
The processing is necessary for
compliance with a legal obligation
; or
•
We have a
legitimate interest
in carrying out the processing for the purpose of
managing risks to which our business is exposed (to the extent that such legitimate
interest is not overridden by your interests or fundamental rights and freedoms).
Fraud prevention:
Detecting, preventing and investigating
fraud.
•
The processing is necessary for
compliance with a legal obligation
; or
•
The processing is
necessary in connection with any contract
that you may enter
into with us, or to take steps prior to entering into a contract with us; or
•
We have a
legitimate interest
in carrying out the processing for the purpose of
detecting, and protecting against, fraud (to the extent that such legitimate interest
is not overridden by your interests or fundamental rights and freedoms); or
•
We have obtained
your prior consent
to the processing (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).
PRIVACY NOTICE - EMEA & APAC - 2026-06