Effective Date: May 15, 2025
1. Our Commitment to Your Privacy
Jafar Management LLC (“Jafar Management,” “the Firm,” “we,” “us,” or “our”) is committed to safeguarding the confidentiality and security of personal information entrusted to us. This commitment is fundamental to our professional obligations as a Registered Investment Adviser and reflects our dedication to maintaining your trust. This Privacy Policy outlines our practices concerning the collection, use, and protection of your personal information. As fiduciaries, we adhere to the highest standards of care, which includes protecting your privacy.
2. Scope of This Policy
This Privacy Policy applies to personal information collected from:
- Visitors to our website, jafarmanagement.com (the “Website”).
- Current and former clients to whom we provide investment advisory services.
- Prospective clients who inquire about our services.
The handling of personal information may differ based on your relationship with us (e.g., as a website visitor or an advisory client) and the applicable legal requirements. For instance, the California Online Privacy Protection Act (CalOPPA) primarily governs information collected from California residents through our Website, while the California Financial Information Privacy Act (CFIPA) and federal laws like the Gramm-Leach-Bliley Act (GLBA) impose specific obligations regarding the “nonpublic personal information” of our advisory clients. This policy aims to address these various requirements comprehensively.
3. Information We Collect
Jafar Management collects personal information to provide investment advisory services and to operate our Website effectively. The types of information we collect depend on your interaction with us.
We may collect the following categories of personal information:
* Identifiers: This includes your real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. As a financial institution, we collect such identifiers to establish and service your accounts and to comply with legal obligations.
* Personal Information Categories Listed in California Civil Code § 1798.80(e): This category includes name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number. We collect relevant information from this category as necessary to provide financial advisory services.
* Financial Information (Nonpublic Personal Information – NPI): This is a critical category for our advisory services and includes information you provide on applications or other forms (such as your income, assets, investment objectives, and risk tolerance), information about your transactions with us, our affiliates, or others (such as account balances, investment positions, and transaction history), and information we may receive from consumer reporting agencies. This NPI is essential for us to provide suitable investment advice and manage your account.
* Internet or Other Similar Network Activity: This includes browsing history on our Website, search queries, interactions with an internet website, application, or advertisement, and information collected through cookies and similar technologies.
* Professional or Employment-Related Information: We may collect information about your occupation, employer, and employment history as part of understanding your financial situation and investment objectives.
We collect personal information through various means:
* Directly from You: When you provide it to us, such as when you complete account applications or other forms, enter into an advisory agreement, communicate with us by mail, telephone, or email, or provide information during meetings.
* Automatically When You Use Our Website: We may collect certain information automatically as you navigate through our Website. This information can include usage details, IP addresses, and information collected through cookies and other tracking technologies.
* From Third Parties: We may receive information from third parties, such as consumer reporting agencies (to assess creditworthiness or verify identity), your custodian(s), brokers, and other financial institutions with whom you have a relationship and authorize to share information with us, or from publicly available sources.
Information Collected Automatically (Cookies and Tracking Technologies):
When you visit our Website, we may use cookies and other tracking technologies to collect certain information automatically. Cookies are small files placed on the hard drive of your computer.
* Types of Information Collected: This may include your IP address, browser type, operating system, referring URLs, information on actions taken on the Website, and dates and times of Website visits.
* Purpose of Collection: We use this information for various purposes, such as to help us improve our Website 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, speed up your searches, and recognize you when you return to our Website.
* Third-Party Data Collection: We may use third-party service providers, such as Google Analytics, to help us analyze how users use the Website. These third parties may use cookies and other tracking technologies to collect information about your use of the Website and other websites over time. CalOPPA requires us to disclose if third parties may collect Personally Identifiable Information (PII) about your online activities over time and across different websites when you use our Website. These third-party services operate under their own privacy policies.
* Managing Cookies: You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
4. How We Use Your Information
We use the personal information we collect for legitimate business purposes, which are directly related to providing you with our investment advisory services and complying with our legal and regulatory duties. CalOPPA requires us to explain why PII is collected, and CFIPA permits the use of NPI to administer transactions and services you request.
* Purposes for Use:
Your personal information may be used for the following purposes:
* Providing Investment Advisory Services: To offer and provide investment advisory services, including assessing your financial situation and investment objectives, formulating investment recommendations, managing your investment portfolio, and executing transactions.
* Client Account Management: To open, maintain, and service your client account(s), including processing transactions and liaising with custodians and brokers.
* Communication: To communicate with you regarding your account, our services, market updates (if you opt-in), and to respond to your inquiries, requests, and feedback.
* Legal and Regulatory Compliance: To comply with applicable laws, regulations, rules, and legal processes, such as those mandated by the Securities and Exchange Commission (SEC), the California Department of Financial Protection and Innovation (DFPI), anti-money laundering (AML) laws, and tax reporting requirements. This includes record-keeping obligations and responding to lawful requests from regulatory bodies.
* Website Operation and Improvement: To operate, maintain, secure, and improve our Website, its content, and our service offerings.
* Internal Business Purposes: For internal purposes such as data analysis, research, audits, developing new products and services, and enhancing our business operations.
* Risk Management: To protect against and prevent fraud, unauthorized transactions, claims, and other liabilities, and to manage risk exposure.
5. How We Share Your Information
Jafar Management is committed to maintaining the confidentiality of your personal information. We do not sell your personal information. We only share your personal information with third parties in the limited circumstances described below, consistent with applicable law and our professional obligations.
* Sharing with Affiliated Companies (if any):
An “affiliate” is a company that we own or control, that owns or controls us, or that is under common ownership or control with us (e.g. Jafar Partners, LLC and Jafar Liquid Strategies LP). Jafar Management nor its affiliated companies shares your personal information for marketing purposes.
* Sharing with Non-Affiliated Third Parties:
A “non-affiliated third party” is a company that is not an affiliate of Jafar Management. We will not share your NPI with non-affiliated third parties for them to market their own products or services to you. CalOPPA also requires disclosure of categories of third parties with whom PII is shared.[3, 6]
We may share your personal information with non-affiliated third parties under the following circumstances, which are generally permitted by law without your specific opt-in consent:
* Service Providers: We may share personal information with service providers who perform essential business operations or services on our behalf. This includes, but is not limited to, auditors, brokerage firms for trade execution, technology service providers (for data processing, software support, website hosting), and other consultants. These service providers are contractually obligated to maintain the confidentiality and security of the information and are restricted from using it for any purpose other than that for which it was disclosed.
* To Service Your Account or Effect Transactions: We share information as necessary to process transactions you request or authorize, such as with clearing agencies or other financial intermediaries.
* Legal or Regulatory Authorities: We may disclose personal information to regulatory authorities (like the SEC or DFPI), law enforcement agencies, or other third parties when required by law, subpoena, court order, or other legal or regulatory process.
* Fraud Prevention and Risk Control: We may share information to prevent fraud, protect the security of our records and systems, respond to an inquiry from a regulator, or as part of an institutional risk control program.
* With Your Consent: We may share information with any other third party with your explicit consent.
* Disclosures Required by Law:
As noted above, we may be required to disclose your personal information to comply with federal, state, or local laws, rules, and other applicable legal requirements; to comply with a properly authorized civil, criminal, administrative, or regulatory investigation or subpoena or summons by federal, state, or local authorities; or to respond to judicial process or government regulatory authorities that have jurisdiction over Jafar Management for examination, compliance, or other purposes as authorized by law.
6. Your California Privacy Rights and Choices
California residents have specific rights regarding their personal information under California law. This section describes those rights and explains how to exercise them.
* Your Rights Under the California Financial Information Privacy Act (CFIPA):
CFIPA provides California consumers with rights concerning their NPI held by financial institutions.
* Right to Control Sharing with Non-Affiliated Third Parties (Opt-In): Jafar Management will not share your NPI with non-affiliated third parties for their own independent use or marketing purposes.
* Right to Control Sharing with Certain Affiliates (Opt-Out): As detailed in Section 5, your rights regarding sharing NPI with our affiliates are governed by both federal law (FCRA) and, for NPI that is not consumer report information, potentially by CFIPA’s opt-out provisions.
* Your Rights Under the California Online Privacy Protection Act (CalOPPA):
CalOPPA provides California residents who use our Website with the following right:
* Right to Review and Request Changes to Your Personally Identifiable Information: You have the right to review and request changes to the PII that we have collected from you through our Website. To do so, please contact us using the information provided in the “Contact Us” section below.
* How to Exercise Your Rights:
To exercise any of the rights described above that are applicable to you, please contact us at:
Email: support@jafarmanagement.com
Phone: (734) 678-8562
We will respond to your requests in accordance with applicable law. We may need to verify your identity before processing certain requests.
* Our Response to “Do Not Track” Signals (CalOPPA disclosure):
CalOPPA requires us to disclose how our Website responds to “Do Not Track” (DNT) signals from web browsers. Some web browsers may transmit DNT signals. Currently, there is no universally accepted standard for how to respond to DNT signals. Therefore, Jafar Management does not currently alter its practices when it receives a DNT signal. We will continue to monitor the development of DNT standards and may update this policy as needed.
Furthermore, as mentioned in Section 3, we may use third-party services like Google Analytics on our Website. These third parties may collect information about your online activities over time and across different websites when you use our Website, and they may not respond to DNT signals. You should review the privacy policies of these third parties for more information on their DNT practices.
* Your California Privacy Rights at a Glance:
| Right | Applicable Law(s) | How to Exercise |
| Control Sharing with Non-Affiliated Third Parties (Requires Opt-In) | CFIPA | Await specific consent form if such sharing is proposed |
| Control Sharing with Certain Affiliates (Opt-Out, if applicable) | CFIPA (as limited by FCRA) | Contact us via methods listed in “How to Exercise Your Rights” |
| Review/Request Changes to Online PII | CalOPPA | Contact us via methods listed in “How to Exercise Your Rights” |
| Know Our “Do Not Track” Policy | CalOPPA | See “Our Response to Do Not Track Signals” section above |
7. Data Security and Confidentiality
Jafar Management takes the security and confidentiality of your personal information seriously.
* Measures to Protect Your Information:
We maintain physical, electronic, and procedural safeguards that are reasonably designed to protect your personal information from unauthorized access, use, alteration, disclosure, or destruction. These measures include, but are not limited to, restricting access to personal information to employees and service providers who need to know that information to provide products or services to you or operate our business, use of encryption technologies where appropriate, and secure storage of records. The DFPI itself notes the use of precautions like encryption and limited employee access. However, it is important to recognize that no security system is impenetrable, and we cannot guarantee the absolute security of your information.
* Client Confidentiality (as per California Code of Regulations §260.238(m)):
As a Registered Investment Adviser in California, Jafar Management and its representatives are bound by specific ethical and regulatory duties concerning client confidentiality. California Code of Regulations, Title 10, Section 260.238(m) prohibits us from “[d]isclosing the identity, affairs, or investments of any client to any third party unless required by law to do so, or unless consented to by the client”. We are committed to upholding this standard of confidentiality as part of our fiduciary duty to you.
8. Data Retention
Jafar Management will retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including to provide you with our services, to satisfy any legal, accounting, or regulatory reporting requirements, and to resolve disputes. Investment advisers are subject to specific record-keeping rules (such as Rule 204-2 under the Investment Advisers Act of 1940 and similar state rules) that dictate minimum retention periods for certain types of client records and communications. Our retention policies are designed to comply with these legal and regulatory obligations.
9. Children’s Privacy
Our Website and our investment advisory services are not directed to or intended for individuals under the age of 18. Jafar Management does not knowingly collect personal information from children under the age of 18 (or 13, in compliance with the Children’s Online Privacy Protection Act – COPPA, for online data collection). If we become aware that we have inadvertently collected personal information from a child under 18 without parental consent, we will take steps to delete such information promptly. If you believe we might have any information from or about a child under 18, please contact us.
10. Changes to This Privacy Policy
Jafar Management may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service offerings. CalOPPA requires that we describe how we notify consumers of material changes to our privacy policy. If we make material changes, we will post the updated Privacy Policy on our Website and update the “Effective Date” at the top of this policy. For existing clients, we may also provide notice of material changes by email or other direct communication. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting the personal information we collect.
11. Contact Us
If you have any questions, concerns, or comments about this Privacy Policy or our privacy practices, or if you wish to exercise your California privacy rights, please contact us at:
Jafar Management LLC
80 Pine Terrace, Tiburon, CA 94920
Email: support@jafarmanagement.com
Phone: (734) 678-8562