PRIVACY INFORMATION FOR OUR CLIENTS
GUIDING PRINCIPLES
The relationship between RCap Securities, Inc. (“RCap”) and our clients is the most important asset of our firm. We strive to maintain your trust and confidence in our firm, an essential aspect of which is our commitment to protect your personal information to the best of our ability. We believe that all of our clients value their privacy, so we will not disclose your personal information to anyone unless it is required by law, at your direction, or is necessary to provide with our services. We have not and will not sell your personal information to anyone.
THE PERSONAL INFORMATION THAT WE COLLECT, MAINTAIN AND COMMUNICATE
RCap collects and maintains your personal information so we can provide investment management services to you. The types and categories of information we collect and maintain about you include:
- Information we receive from you to open an account or provide investment advice to you (such as your home address, telephone number, and financial information);
- Information that we generate to service your account (such as trade tickets);
- Information that we may receive from third parties with respect to your account (such as trade confirmations from brokerage firms).
In order for us to provide investment management services to you, we do disclose your personal information in very limited circumstances, which include:
- Disclosures to companies – subject to confidentiality agreements – that perform services on our behalf (such as technology consultants who assist us in maintaining our computer systems); and
- Disclosures to companies as permitted by law, including those necessary to service your account (such as providing account information to brokers and custodians).
HOW WE PROTECT YOUR PERSONAL INFORMATION
To fulfill our privacy commitment at RCap, we have instituted firm-wide practices to safeguard the information that we maintain about you. These include:
- Adopting policies and procedures that put in place safeguards for your personal information.
- Limiting access to personal information to those employees who need it to perform their job duties.
- Requiring third parties that perform services for us to agree to keep you information strictly confidential.
- Protecting information of our former clients to the same extent as our current clients.
AFFILIATE MARKETING
The Securities and Exchange Commission (SEC) recently adopted Regulation S-AM. Regulation S-AM allows a consumer, in certain limited situations, to block affiliates of investment advisers from soliciting the consumer based on eligibility information (i.e., certain financial information, such as information regarding consumer’s transaction or experience with the investment adviser. RCap does not allow its affiliates to utilize eligibility information to solicit its clients for marketing purposes. Should RCap change its policies regarding affiliated marketing based on eligibility information, an updated policy will be provided with the ability to opt out prior to such changes.
OPT OUT
Should RCap change its policies regarding sharing your personal information (including with its affiliates), we will provide you with an updated policy and the ability to opt out prior to such changes.
QUESTIONS
Questions regarding this notice can be directed to your RCap representative at 646-829-0141.