Privacy Notice

Last Updated:October 5, 2026

OUR COMMITMENT TO PRIVACY

JMI Management, L.P. (“JMI”, “we”, “us”, “our”) recognizes that your privacy is important. When you interact with the publicly accessible portions of this web site or our JMI branded event engagement application (each a “Site”, collectively “Sites”), visit our offices, attend our events or conferences, or otherwise communicate with us (collectively, “Services”) or apply for a job with us, we may collect and process certain information about you, including information that is considered “personal information” or “personal data” under applicable law (“Information”).  This Privacy Notice (the “Notice”) details the types of Information we may collect about you, how we may use such Information, how and to whom we may disclose your Information, how we protect your Information and your rights and choices with respect to your Information, as well how you may exercise such rights and choices.

This Notice does not cover or include any of JMI’s advisory or investment services or the investor portal accessible via the Site. If you are an investor in a fund or the holder of an account managed directly or indirectly by us (or, in either case, their representative), please refer to JMI’s Notice Regarding Privacy of Financial Information, Privacy Notice for California Residents (if applicable) or GDPR Privacy Notice (if applicable), available in our investor portal or otherwise provided to you, for further information about how JMI collects and processes personal information about its current, prospective, and former investors.

This Notice Describes:

• Information We Collect and How We Collect It
• How We Use Your Information
• Cookies and Other Technologies
• Disclosure of Your Information
• Protection of Your Information
• Retention of Your Information
• Third-Party Sites
• Your Choices and Rights
• Children’s Privacy
• Changes to this Notice
• Questions or Complaints
• California Supplement
• EEA and UK Supplement
• Cookie Notice

THE INFORMATION WE COLLECT AND HOW WE COLLECT IT

In the course of your use of or interaction with our Services or when you apply for a job with us, we may collect Information about you. This may include:

Information we collect directly from you:
We may collect your Information directly from you when you interact with us or our Services or seek employment with us. For example, you may provide us your Information when you are interested in working with us or for us, or one of our portfolio companies (e.g., submit a job application). You may provide us with information about yourself when you are seeking investment into your business. You also may provide us Information when you subscribe to our newsletters or other communications, attend our events (including when you use our event engagement application), visit our office locations, or use or inquire about any of our services.  If you are a supplier of services to JMI, you also may provide us your Information to provide us services. Such Information includes:

• Name and Contact Information– such as your first and last name, mailing or physical address, email address, telephone number, and other contact information;
• Account Data and Profile Information – If you use JMI’s event engagement application, you will create an account name/user ID and password and may provide other information in connection with your user profile, such as your biography, event or session interests, networking preferences or interests, and account preferences (e.g., language preferences).
• Demographic Data– such as your age or date of birth, nationality, ethnicity, race, sex, gender, marital status and military or veteran status;
• Professional or Employment Information– such as your job title or position, employment status, employer name, previous positions, training information, professional experience (resume information, education, etc.) and other information you may provide us in our course of dealings and in connection with managing our relationship;
• Government Issued Identifiers– such as your Social Security Number or other national identification numbers, passport numbers, driver’s license number, or state identification number.
• Financial Information – such as bank account information or tax ID number.
• Health Information – such as information about your health, including any medical condition, dietary restrictions or disability.
• Photographs and Audio Information– such as photographs, audio recordings or voicemails you may leave us and, if you create an account on our event engagement application, you may upload a photo in connection with your user profile.
• Other Information– any other Information you may choose to provide, including information you provide when you communicate with us (e.g., contents of your email, voicemails, or other communications) and information you provide in connection with your registration or attendance of a JMI event, or your use of JMI’s event engagement application (e.g., chat messages, posts or comments, meeting notes, surveys, polls or session scores).

Information we automatically collect: When you use or interact with our Sites, we may automatically collect certain Information through the use of cookies or other similar technologies, including the Information detailed below. For more information about such technologies, view the Cookies and Other Technologies section below.

• Device information: this includes Information, such as your device ID, the browser you are using and its display settings, your operating system, device type, session start/stop time, time zone and network connection (e.g., Wi-Fi, cellular).
• Internet or other electronic network activity information: our Sites may collect or use your internet protocol (IP) address, unique identifiers, and other information regarding your interaction with our Sites.
• Geolocation Data: our Sites may use information regarding your general location. We do not collect or process precise geolocation data.
• Clickstream and Usage Data: We also collect information regarding your interactions with our Sites. This Information includes your activities on our Sites (such as the links you click, the page you visited before navigating our Sites, the content you view, hover, or click on and search terms you enter on our Sites), interaction with our chat features (if applicable), and usage patterns (such as the length of time you use our Sites, error reports, page load times).

Information from third parties:
We may collect Information about you from third parties, such as service providers that perform services for us or on our behalf. We also may receive your Information from agencies conducting credit reference checks and background checks. We also may collect Information from publicly available sources, such as public databases, industry associations, social media, and online professional networks, subject to your privacy settings on the relevant social media platforms or networks. Such Information includes:

• Credit Information– such as your credit score and credit history.
• Background Information– such as driving records, criminal history and information regarding liens or judgements against you which we may collect in connection with background checks we may perform.
• Social Media Data – such as Information about you or your posts on publicly available websites or social media platforms, including your username(s) or social media handle(s), posts, comments, content and any information that accompanies those posts, your likes or preferences or profile picture, subject to your privacy settings on these websites or platforms. If you use our event engagement application and connect your account with your accounts on third-party social media platforms, we also may receive certain Information about you from such platforms.

HOW WE USE OF YOUR INFORMATION

We may use your Information for the following purposes:

• Provision of and Improvement of Services: for the provision of our Services, including management and administration of our Sites, provision of technical or other customer support to resolve technical issues, and improvement of our Services, such as personalizing your experience using our Sites, building and testing new features on our Sites, and analyzing our Sites’ performances.
• Business Function Purposes: To support and enable our business functions, e.g., to maintain and support our internal business functions, including finance, accounting, and auditing; to invoice you or pay you or the organization you represent.
• Communication Purposes: To communicate with you, e.g., respond to your inquiries and other communications and provide our Services; communicate with you about services and events offered by JMI and others and provide news and information that we think will interest you; send you informational materials regarding our products or services or show you relevant advertising.
• Visitor or Event Management Purposes: To manage our event invitations, register your attendance at our offices or events (including training, forums, webinars, conferences), whether online or in person, to book accommodation, and to otherwise manage such visits and manage or administer such events, including connecting you with other attendees and gaining insight about your experience attending our events.
• Security Purposes: To help maintain the safety, security, and integrity of our Sites, including to detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity.
• Compliance Purposes: To comply with our legal and financial obligations, including to respond to law enforcement requests as required by applicable law, court order or governmental regulations.
• Management of Career Opportunities: To manage career opportunities with us, including to evaluate your job qualifications and suitability for the desired position and respond to your application.
• Management of Business Relationships: To conduct business with you/the business you represent and otherwise maintain business relationships; to manage our relationships with current or prospective partners, vendors and other business partner personnel, and attendees of our events; and to consider prospective investment and other due diligence prospects.
• Corporate Transaction Purposes: To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of all or any portion of our, our affiliates’, or a JMI fund’s assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding.
• Protection of Rights: To protect the rights and property of JMI and to otherwise enforce our rights, such as enforcing our Terms of Use.
• Other Purposes: For any other purpose(s) disclosed by us when you provide the Information.

COOKIES AND OTHER TECHNOLOGIES
When you interact with our Sites,  we may use cookies or other similar technologies such as local storage, web beacons, pixel tags, and software development kits (SDKs) to automatically collect Information about you, your device and your interaction with our Site (such as your IP address, web browser, pages viewed, time spent on pages, and links clicked).

Cookies are small data files stored on your computer or device at the request of a website to recognize your browser or to store information or settings in your browser. A cookie assigns a unique numerical identifier to your web browser or device to recognize you as the same user who was at our Sites in the past and relate your use of our Sites to other Information about you. For example, these technologies may allow you to access features that are fundamental to the Services and for security; help us remember your Information so you do not have to re-enter it; track and understand how you use and interact with our Sites; perform analytics and measure the usability of our Sites; customize the Sites around your preferences; manage and enhance our Sites to ensure it is working properly. Most browsers can be set to detect cookies and give you an opportunity to reject them, but refusing cookies may, in some cases, inhibit or preclude your use of our Sites or their features. A pixel tag (also known as a “clear gif” or “web beacon”) is a tiny image that links webpages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. We may use pixel tags to help us measure the effectiveness of our content by, for example, counting the number of individuals who visited our Sites or verifying whether you’ve opened one of our emails. For more information about these technologies and how to disable them, see the Your Choices and Rights section below.

DISCLOSURE OF YOUR INFORMATION

We may share your Information as follows:

• Affiliates and Subsidiaries– we share your Information with our affiliates and subsidiaries in connection with any of the uses of your Information set out in this Notice.
• Vendors and Service Providers– we share your Information with our vendors and service providers that perform services for us or on our behalf, such as server hosts, email service providers, IT service providers and AI tool providers, investor relations management platform providers, background and media check providers, marketing agencies or providers, and analytics providers who assist us in the improvement and optimization of the Sites.
• Professional Advisors – we may share your Information with our professional advisers, including consultants, lawyers, bankers, auditors, public relations agencies, and insurers who provide consultancy, banking, legal, insurance and accounting services to support our Services.
• Recruitment Agents – we may share your Information with our recruitment agents, referees, and other similar providers who support in recruitment and management efforts, including credit reference agencies, social media and media monitoring services.
• Business Partners – we may share your Information with our business partners, such as our event co-sponsors or other strategic partners.
• Other Event Attendees – we share with our event attendees a list of the attendees and their business contact information, if you use our event engagement application and interact with other attendees via the application, we may share certain Information in connection with your interaction with such attendees.
• Others –We may also disclose your Information to other parties if you ask, authorize, or direct us to do so, or where we are otherwise permitted to by law.
• Compliance with Law and Enforcement Entities– we may disclose your Information (i) if we believe it is necessary in order to investigate, prevent, or take action regarding inappropriate or illegal activities, fraud, or situations involving potential threats to the safety of any person or property (including if we believe it is necessary to investigate, prevent, or take action regarding abuse of our Sites’ infrastructure); (ii) in response to requests by government agencies, such as law enforcement authorities, or investigations of suspected or actual illegal activity; (iii) to establish, exercise or defend our legal rights (e.g., enforce our Terms of Use); or (iv) to comply with legal obligations, and legal processes (e.g., subpoena or court order) and procedures.
• Mergers and Acquisitions– we may disclose your personal information to third parties in the event we sell or transfer (or contemplate the sale or transfer of) some or all of our, our affiliates’ or a JMI fund’s assets or in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution, or liquidation of our or an affiliates’ business, and such third parties may use your personal information in the same way as set out in our Privacy Notice.
• Deidentified and Aggregated Information– we may aggregate and/or de-identify your Information such that it is no longer able to be linked to you or your device(s). This Notice does not limit our ability to use or disclose such aggregated or de-identified information, which we may disclose in our sole discretion.

PROTECTION OF YOUR INFORMATION
The security and confidentiality of your Information is very important to us. We have implemented administrative, technical, and physical safeguards designed to appropriately protect your Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, no security measures can guarantee that information will never be accessed in an unauthorized way.

RETENTION OF YOUR INFORMATION
We will retain your Information for as long as reasonably necessary to fulfill the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. We may also retain your Information to investigate or defend against potential legal claims in accordance with the limitation periods of jurisdictions where legal action may be brought. The length of time we hold your Information will be determined by various criteria, including the nature and sensitivity of the Information, purposes for which we are using your Information, our legal obligations related to the personal information (including any applicable statutes of limitations and records retention requirements), and the risks associated with retaining the Information. Generally, we endeavor not to keep Information in an identifiable form for any longer than is needed. At the end of the applicable retention period, we may destroy, erase from our systems, or anonymize personal information as part of such efforts.

THIRD-PARTY SITES

This Privacy Notice applies only to the Sites. Our Sites may contain links to other websites not operated or controlled by JMI (the “Third-Party Sites”). The practices we describe in this Notice do not apply to the Third-Party Sites. The links from our Sites do not imply that JMI endorses or has reviewed the Third-Party Sites. The privacy notices made available on the Third-Party Sites govern the collection and use of your Information by those sites. We suggest reviewing those privacy notices to learn more about how your Information will be used by those third parties or contacting those sites directly for information on their privacy practices.

We maintain a presence on certain social media platforms, such as LinkedIn, to communicate with our clients or limited partners. This Privacy Notice applies to our use of personal information you submit to us on such platforms or receive about you from such platforms, but it does not apply to what those third‑party platforms do with your personal information. These platforms have their own privacy policies. In accordance with those policies (and your privacy settings within your social media accounts), information about your activities on our Site or the relevant social media platform (such as “John follows JMI”) may be published to your social media account.

YOUR CHOICES AND RIGHTS

Email Communication Preferences: If JMI sends you email communications about services that we think may be of interest to you, you may opt-out of receiving such communications by following the instructions set forth in such communications, by clicking the “unsubscribe” link at the bottom of the email. In addition, if at any time you wish not to receive any future email communications or you wish to have your name deleted from our mailing lists, please contact us at compliance@jmi.com.

Browser and Device Settings: Your browser may tell you how to be notified about certain types of cookies and how to restrict or disable them. To learn more about how to manage cookies on different browsers, you can visit the website www.allaboutcookies.org or https://ico.org.uk/your-data-matters/online/cookies/.  Note that blocking these technologies may prevent you from being able to use some or all of the features of our Sites. Your browser may also permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking.  We do not currently respond to “Do Not Track” signals. For mobile devices, you can manage how your browser and device share certain data by adjusting the privacy and security settings on your device settings. If you have opted-in to receive push notification on your device, you can opt-out at any time by adjusting the permissions on your device or uninstalling our application.

You may also change your cookie preferences at any time through our cookie preference tool. To access the tool, click on “Cookie Preferences” in the footer of our Site or the cookie icon at the bottom left of our Site.

Privacy Rights: In addition to the choices noted above, depending on the jurisdiction of your residence, you may be afforded, in accordance with applicable law, certain rights with respect to your Information. If you are a resident of California, please see our California Supplement for more information. If you are a resident of the EEA or UK, please also see our EEA and UK Supplement.

CHILDREN’S PRIVACY

JMI does not knowingly collect Information from individuals who are under 16 years old. If you are a parent or legal guardian and you believe we have collected your child’s Information, please contact us at compliance@jmi.com.

CHANGES TO THIS NOTICE
This Notice may change from time to time and, therefore, you are strongly encouraged to review this Notice regularly to stay informed about our privacy practices. If we make changes to this Notice, we will post those changes in an amended version of this notice. In some cases, we may provide you with additional notice (such as adding a statement to our website or sending you notification).

QUESTIONS OR COMPLAINTS

If you have a question about this Notice or a complaint about our privacy practices, please contact us at compliance@jmi.com.

All correspondence with JMI regarding employment opportunities at JMI should be sent to, and will come from, an employee-specific JMI email (ex: jdoe@jmi.com) ending in the domain @jmi.com and candidates are advised that any offer will come from such an employee-specific JMI email.

California Supplement

Last Updated:October 5, 2026

This California Supplement (“CA Supplement”) provides information for residents of California (“you”). This CA Supplement should be read with our Privacy Notice to fully understand our collection, use and disclosure of your personal information.

For purposes of this CA Supplement, “personal information” shall mean any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to any individual or a household. Any other terms used here and not otherwise defined in our Privacy Notice shall have the meanings given to them in the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq., as amended, and the regulations promulgated thereunder (collectively, the “CCPA”).

Personal Information We Collect: We may collect (and may have collected within the last twelve (12) months) the following categories of personal information for the purposes of processing described in the How We Use Your Information section of our Privacy Notice:

• Identifiers, such as name, contact information (e.g., email address, physical address, telephone number), account name/user ID, online identifiers (e.g., device IDs).
• Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e), such as name, signature, your government identification numbers (e.g., driver’s license number, Social Security Number, driver’s license number or state identification number) and bank account information.
• Protected classification characteristics under California or federal law, such as age, race, gender, ethnicity, national origin, citizenship/immigration status, marital status, veteran or military status, or information concerning your health.
• Internet or other electronic network activity information, such as searches or browsing histories on our Sites, information about your interactions with our Sites (e.g., pages viewed, links clicked).
• Geolocation information, such as approximate (non-precise) location information.
• Sensory data, such as audio, electronic, visual, and similar information, such as photographs for identification or security purposes, photographs at our hosted events, video and call recordings.
• Professional or employment-related information, such as, your job title, job history and employment information, background check information and professional experience.
• Education information, such as your education and training background and information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).
• Inferencesdrawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Sensitive Personal Information

Certain categories of personal information listed above may be considered sensitive personal information as defined under the CCPA. We do not collect or use sensitive personal information for the purpose of inferring characteristics about you.  We do not use or disclose sensitive personal information for any purposes other than the purposes permitted under the CCPA.

Sources of Personal Information: We collect (and may have collected within the last twelve (12) months) the categories of personal information above from you and from the following categories of sources:

• our affiliates and subsidiaries;
• our vendors and service providers who perform services for us or on our behalf;
• our business partners, such as our event co-sponsors or other strategic partners; and
• recruitment agents and data brokers, such as background check services, and any references you provide to us, such as when applying for an employment opportunity.

Disclosure of Personal Information: We may disclose (and may have disclosed within the last twelve (12) months) the categories of personal information above to the following third parties for the purposes of processing described in the How We Use Your Information section of our Privacy Notice:

• our affiliates and subsidiaries;
• our vendors and service providers who perform services for us or on our behalf;
• our professional advisors;
• our business partners, such as our event co-sponsors or other strategic partners;
• recruitment agents and data brokers, such as background check services; and
• other third parties, if you ask or direct us to disclose your personal information.

We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries. We also may disclose your personal information to third parties in the event we sell or transfer (or contemplate the sale or transfer of) some or all of our, our affiliates’ or a JMI fund’s assets or in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution, or liquidation of our or an affiliates’ business, and such third parties may use your personal information in the same way as set out in our Privacy Notice and this Supplement.

Sale or Sharing of Personal Information: We do not sell or share, as such terms are defined in the CCPA, your personal information.  We do not sell or share, as such terms are defined in the CCPA, any personal information of individuals under the age of 16.

Your Rights:
The CCPA provides you with specific rights to your personal information, subject to certain exceptions. This section describes your CCPA rights and explains how you may exercise such rights.

• Disclosure and Access Rights:You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale or share (as such terms are defined in the CCPA) of personal information specific to you and subject to certain exceptions. Such information includes:
  • the categories of personal information we collected about you
  • the categories of sources from which we collected your personal information
  • our business or commercial purpose(s) for collecting or disclosing that personal information
  • the categories of third parties with whom we disclose personal information
  • if we disclosed your personal information for a business purpose, the categories of personal information disclosed and the categories of recipients to whom we have disclosed personal information
  • the specific pieces of personal information we collected about you
• Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions. For example, we may deny your correction request if we determine that the contested information is more likely than not accurate. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
• Deletion Right: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions, including, but not limited to, retaining such information for purposes of our compliance with applicable law, rules, and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

How to Exercise Your Rights:
For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.

Call us using the following phone number: (410) 951-0200. If you would like to contact us by telephone without incurring telephone charges, please submit your request and telephone number by email at the following address compliance@jmi.com, and we will call you between 9 a.m. and 6 p.m. Eastern Time.

Email us at the following email address: compliance@jmi.com.

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request your email address and phone number in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.

We will not discriminate against you for exercising your rights under the CCPA, such as denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

Changes to this Supplement:
We may modify or update this CA Supplement from time to time. We encourage you to revisit this CA Supplement often to remain fully informed of our privacy practices. If we make changes to this CA Supplement, we will post those changes in an amended version of the supplement. In some cases, we may provide you with additional notice (such as adding a statement to our website or sending you notification).

Questions about this CA Supplement:
If you have any questions about this CA Supplement or our privacy practices, please do not hesitate to contact us at compliance@jmi.com.

EEA and UK Supplement
Last Updated:October 5, 2026

This EEA and UK Supplement provides data protection related information for residents of those jurisdictions and applies to the extent that the data protection laws of the EEA and UK apply to JMI.

To the extent applicable, we (JMI Management, L.P.) will be the controller of your Information provided to, collected by or for, or processed by us for the purposes set out below.

This EEA and UK Supplement should be read alongside the Notice. Any capitalized terms not defined in this EEA and UK Supplement are defined in the main section of the Notice.

Legal Basis for processing your Information
Under data protection laws in the UK and EEA, we can only use your Information if we have a valid reason. The most common lawful bases we rely upon are as follows:

• where you have given consent (“Consent”);
• to comply with our legal obligations (“Legal Obligations”);
• for the performance of a contract with you or to take steps at your request before entering into a contract (“Contract”); or
• for our legitimate interests or those of a third party, so long as this is not overridden by your own rights and interests (“Legitimate Interests”).

We do not process Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data, biometric data processed for the purpose of identification, data concerning health, or data concerning sex life or sexual orientation (“Special Category Personal Data”) and in some cases criminal records information, unless permitted by applicable law and a condition is in place. Where a condition is required, usually this will mean:

• that the processing is legally required under applicable law (“Legal Obligation”);
• where there is a substantial public interest (“Substantial Public Interest”);
• to establish, exercise or defend legal claims (“Legal Claims”); or
• where you have provided explicit consent (“Explicit Consent”).

As noted in the Notice, the nature of your interaction with us will determine how we will process your Information. The table below sets out the Information that will be used for the relevant specific purposes, alongside the applicable lawful basis:

 

Purpose	Information	Legal Basis for Processing
Provision of and Improvement of Services	Name and Contact Information Account Data and Profile Information Government Issued Identifiers Professional or Employment Information Financial Information [and Payment Card Information] Photograph and Audio Information Other Information Device Information Internet and other electronic network activity information Geolocation Data Clickstream and Usage Data Social Media Data	Contract Or, if not, Legitimate Interests (to provide and improve our Services) Consent for processing through cookies and similar technologies where required, as described in the Cookie Notice
Security Purposes	Device Information Internet and other electronic network activity information Geolocation Data Clickstream and Usage Data	Legitimate Interests (to maintain security)
Business Function Purposes	Name and Contact Information Professional or Employment Information Financial Information Other Information	Contract Or, if not, Legitimate Interests (to operate the business)
Communications Purposes	Name and Contact Information Account Data and Profile Information Professional or Employment Information Social Media Data	Contract Or, if not, Legitimate Interests (to communicate with relevant persons)
Visitor or Event Management Purposes	Name and Contact Information Account Data and Profile Information Government Issued Identifiers Professional or Employment Information Financial Information Photograph and Audio Information Other Information Health Information Device Information Internet and other electronic network activity information Geolocation Data Clickstream and Usage Data Social Media Data	Consent (for processing through cookies and similar technologies where required) Or, if not, Legal Obligations Or, if not, Contract Or, if not, Legitimate Interests (for operational purposes and to organise and administer visits and events) Special Category Personal Data Condition: Where we process Health Information for this purpose, we rely on your Explicit Consent.
Management of Career Opportunities	Name and Contact Information Demographic Data Professional or Employment Information Government Issued Identifiers Other Information Health Information Credit Information Background Information Social Media Data	Consent Or, if not, Legal Obligations Or, if not, Contract Or, if not, Legitimate Interests (to assess candidacy)   Special Category Personal Data: Legal Obligations (to comply with employment obligations); Substantial Public Interest (where an applicable statutory condition permits the processing) or Explicit Consent
Management of Business Relationships	Name and Contact Information Professional or Employment Information Government Issued Identifiers Other Information Credit Information Background Information Social Media Data	Legal Obligations Or, if not, Contract Or, if not, Legitimate Interests (to manage relationships and investments and to otherwise operate the business)
Corporate Transaction Purposes	Name and Contact Information Professional or Employment Information Other Information	Legitimate Interests (to operate the business)
Compliance Purposes	Name and Contact Information Professional or Employment Information Other Information Photographs and Audio Information	Legal Obligation Or, if not, Legitimate Interests (to comply with our obligations)
Protection of Rights	Name and Contact Information Professional or Employment Information Other Information Photographs and Audio Information	Contract Or, if not, Legitimate Interests (to protect the business)

Failure to provide us with the relevant Information, in cases where you are legally or contractually required to provide it, may result in our being unable to establish or continue our relationship with you or to provide Services to you.

We will only use your Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

Transfer of Data Outside the UK & EEA
We operate from the USA, and any information that we collect, disclose or share, including your personal data, will be stored and processed in various other jurisdictions around the world.

To the extent required, we ensure we have in place applicable contractual arrangements with third parties in respect of such transfers that accord with applicable laws, including the European Commission’s standard contractual clauses and, for UK transfers, the UK International Data Transfer Addendum or International Data Transfer Agreement, as applicable.

You can obtain more information about our policies and practices with respect to the use of third parties located in other jurisdictions by contacting us at compliance@jmi.com.

Data Subject Rights
If you reside within the EEA or the UK, you may request to:

• Receive confirmation as to whether or not Information concerning you is being processed, and access your stored Information, together with supplementary information.
• Receive a copy of Information you directly volunteer to us in a structured, commonly used and machine-readable format.
• Request rectification of your Information that is in our control.
• Object to the processing of Information by us.
• Request to restrict processing of your Information by us.
• Request erasure of your Information.
• Lodge a complaint with a supervisory authority.

Where we rely on your Consent or Explicit Consent, you may withdraw it at any time by contacting us at compliance@jmi.com, without affecting the lawfulness of processing before withdrawal.

Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. ​If you, as an EEA or UK resident, would like to exercise any of the rights mentioned in this section, please contact us at compliance@jmi.com.

COOKIE NOTICE

Last Updated: October 5, 2026

As noted in the “Cookies and Other Technologies” section of our Privacy Notice, when you visit or interact with our Sites or email communications, we collect certain Information about you and your devices by automated means, using cookies, web server logs, pixel tags, SDKs or other similar technologies. Any capitalized terms we do not define in this Cookie Notice are defined in our Privacy Notice.

Cookies are small data files that websites send to your computer or device to uniquely identify your browser or to store information or settings in your browser. Cookies enable us to recognize you as the same user who was at our Sites in the past and relate your use of our Sites to other personal information about you. We may use cookies to help us remember your Information so you do not have to re-enter it; track and understand how you use and interact with our Sites; perform analytics and measure the usability of our Sites; customize the Sites around your preferences; manage and enhance our Sites to ensure it is working properly.

We may use the following categories of cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our Sites. They include, for example, cookies that are necessary for the Sites to function, cookies that enable you to log into secure areas of the Sites or cookies set in response to your request for services.
• Performance cookies. These cookies allow us to measure and improve the performance of our Sites. These include cookies that count the number of visitors of our Sites, identify the traffic sources, and record your interactions with our Sites (e.g., your navigation path on the Site, pages visited, content viewed, links clicked).
• Functional cookies. These cookies allow us to provide enhanced functionality, a personalized digital experience (e.g., remembering your preferences and settings) and certain support features.
• Targeting cookies. These cookies allow us and our advertising partners to understand our interactions with you and deliver tailored advertising. These cookies enable us and our partners to build profiles of your interests, show you tailored advertisements, and track the effectiveness of our advertising campaigns.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

JMI Website:

Cookie	Purpose	Cookie Category	Duration
_ga	Set by Google Analytics to distinguish unique users by assigning a randomly generated client ID	Performance	2 years
_ga_<container-id>	Set by Google Analytics 4 to persist session state and track user activity across page views	Performance	2 years
cookieyes-consent	Set by CookieYes to store the user’s consent preferences for CookieYes (accepted/rejected categories, consent ID, and timestamp).	Strictly Necessary	1 year

 

JMI Application:

Cookie	Purpose	Cookie Category	Duration
[event abbreviation]_ publicPortal_ CookiesPoliciesSettings_ [hash]	Set by Swapcard to store the user’s cookie-consent selections for the public portal. The exact cookie name is generated dynamically.	Strictly Necessary	1 year
lastLandingPageId	Set by Swapcard to return the user to the same starting page after completing a registration flow.	Strictly Necessary	24 hours
Randomly generated hash (Session ID)	Set by Swapcard to temporarily store information about the user and their interactions with the platform during the session.	Strictly Necessary	Session
timeCheck	Set by Swapcard to track the remaining time before the user’s server-side session expires.	Strictly Necessary	Session
profileEmail	Set by Swapcard to temporarily store the registered user’s email so that social email-sharing functions can pre-populate the sender address.	Strictly Necessary	1 hour
timeCheckMessage	Set by Swapcard to store information used to display the alert shown after a password-reset request.	Strictly Necessary	1 hour
timeCheckRedirect	Set by Swapcard to store the destination to which a user should be redirected after using the password-reset functionality.	Strictly Necessary	1 hour
_ga	Set by Google Analytics to distinguish users for Google Analytics.	Performance	2 years
_ga_[container ID]	Set by Google Analytics to persist the Google Analytics session state.	Performance	2 years
_gcl_au	Set by Google Analytics to help analyze how visitors use the site and supports analytics reporting.	Performance	2 years
_gid	Set by Google Analytics to register a unique identifier used to generate statistical information about usage.	Performance	2 years

 

Most browsers can be set to detect cookies and give you an opportunity to reject them, but refusing cookies may, in some cases, inhibit or preclude your use of our Sites or certain features. To learn more about how to manage cookies on different browsers, you can visit the website www.allaboutcookies.org or https://ico.org.uk/your-data-matters/online/cookies/. Your browser may also permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking. We do not currently respond to “Do Not Track” signals.

You may also change your cookie preferences at any time through our cookie preference tool. To access the tool, click on “Cookie Preferences” in the footer of our Site or the cookie icon at the bottom left of our Site.

To the extent a legal basis is required by applicable data protection laws, the legal basis for any processing of your personal information in connection with the use of performance cookies, functional cookies or targeting cookies is your consent. You can revoke your consent (if given) at any time, by changing your cookie preferences on our cookie preference tool. However, such revocation will have no effect on the lawfulness of the processing that took place before you revoked your consent.

 

The legal basis for any processing of your personal information in connection with the use of strictly necessary cookies is that it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.