CONFIDENTIALITY AND PRIVACY POLICY NOTICE
Rocktop Partners, LLC (together with its affiliates, “Rocktop”) is required to adopt certain procedures designed to protectconfidential and nonpublic information of its clients and investors (collectively, “Clients”) and to safeguard personalinformation contained in both paper and electronic records. This policy (the “Privacy Policy”) is governed by anddesigned to meet the standards set forth in the federal and state regulations of the United States of America (to the extentthat such regulations and standards are applicable).
Client Information
Rocktop collects and keeps information that is necessary to provide the services requested by Clients and toadminister Rocktop’s business. For instance, Rocktop may collect nonpublic personal information (such as name, address, social security number, assets, income, net worth, copies of financial documents and other information deemed necessary to evaluate a prospective Client’s financial needs) from Clients when they complete a subscription or other form or through discussions with Clients or prospective Clients. Rocktop may also collect personalinformation related to Clients’ account histories, Client transactions with Rocktop and correspondence (telephonic orelectronic) between Rocktop and Clients or prospective Clients.
Sharing Information
Rocktop shares the nonpublic personal information of Clients with unaffiliated entities or individuals (i) as permittedby law and as required to provide services to the Rocktop’s clients; (ii) to comply with legal or regulatoryrequirements; or (iii) as authorized by the individual to whom the nonpublic personal information relates. Rocktopmay also disclose nonpublic personal information to another financial services provider in connection with thetransfer of an account to such financial services provider. Further, in the normal course of business, Rocktop maydisclose information it collects about Clients to entities or individuals that contract with Rocktop to performservicing functions such as recordkeeping or computer-related services. Rocktop may also make a good faithdisclosure of the nonpublic personal information to regulators who have regulatory authority over Rocktop. Finally,Rocktop may disclose nonpublic personal information in connection with a corporate transaction, for example, if Rocktop is sold or transferred to a third party.
Companies hired to provide support services to Rocktop are not allowed to use personal information for their ownpurposes. When Rocktop provides personal information to service providers, only the information that is necessary toperform the service is provided.
Rocktop does not (i) provide personally identifiable information to mailing list vendors or solicitors for any purpose,or (ii) sell information relating to its Clients to any outside third parties.
Protection of Information
Rocktop maintains reasonable and prudent security standards designed to protect Client information, whetherwritten, spoken, or electronic. No security is perfect, however, and Rocktop therefore cannot guarantee theprotection of the nonpublic personal information provided to it. Please notify Rocktop promptly if you becomeaware of any unusual activity involving any accounts you have with Rocktop. Rocktop also maintains reasonable and prudent restrictions upon physical access to records containing personal information.
Maintaining Accurate Information
Rocktop’s goal is to maintain accurate, up-to-date Client records in accordance with industry standards.
Should a Client send Rocktop a question or comment via e-mail, Rocktop will share such correspondence withthose employees or agents as are necessary for the purpose of addressing the question or concern. All writtencommunications pertaining to such question or comment will be retained by Rocktop until such time as Rocktopbelieves that it has provided the Client with a complete and satisfactory response or otherwise in accordance withRocktop’s internal policies and applicable law. After that time, Rocktop may discard the communication or archive itaccording to its data retention policies and the requirements of applicable laws.
Please note that, unless expressly advised otherwise, Rocktop’s e-mail facilities do not provide a means forcompletely secure and private communications. For that reason, use caution when using e-mail to communicate information to Rocktop that is considered to be confidential. If a Rocktop Client wishes, communications withRocktop may be conducted via telephone or by facsimile.
Disclosure of Privacy Policy
Rocktop recognizes and respects the privacy concerns of potential, current and former Clients. Rocktop is committed tosafeguarding this information. As a member of the financial services industry, Rocktop provides this Privacy Policy forinformational purposes to its Clients and employees and will distribute and update it as required by law. The PrivacyPolicy is also available upon request.