PRIVACY POLICY OF
ROCKWELL GLOBAL CAPITAL LLC

 

The following information contains Rockwell Global Capital LLC’s (“Rockwell”) privacy policy designed to protect the confidentiality of current or former customers (“you”) of Rockwell.  Rockwell has established a relationship with you as a result of your opening a brokerage account with Rockwell.  This means we receive your nonpublic personal information for the sole purpose of servicing your account.

This information is presented to you in conformity with 15 U.S.C. 6801-6810 and the Securities and Exchange Act of 1934 as amended by 15 U.S.C. 6801-6810.  The nonpublic personal information which identifies you or your account is hereafter referred to as “personal information”.

Maintaining personal information secure and confidential is a Rockwell priority.  We take precautions to safeguard client personal information at all times, and we will remain vigilant in protecting that information.  The following information will explain our privacy policy in more detail.

YOUR NONPUBLIC PERSONAL INFORMATION.

ROCKWELL DOES NOT SELL YOUR NONPUBLIC PERSONAL INFORMATION.  WE WILL ONLY DISCLOSE YOUR NONPUBLIC PERSONAL INFORMATION, WHICH INCLUDES ANY PERSONALLY IDENTIFIABLE INFORMATION ABOUT YOU, AS INDICATED IN THIS POLICY, IF WE HAVE OBTAINED YOUR CONSENT OR WE ARE REQUIRED BY LAW TO DISCLOSE SUCH INFORMATION.

NONPUBLIC PERSONAL INFORMATION COLLECTED.
In order to provide you with the highest quality of service, Rockwell collects the following types of nonpublic personal information:

1. Information from you.
1. Information you provide on an application for an account, or any other financial product or service, whether in writing, in person, by telephone, electronically or by any other means, such as your name, address, social security number, assets, income, and debt; and
2. Information we obtain for the purpose of tax reporting to you and to the various agencies to which we report as required by law, including disclosures on various Internal Revenue Service (IRS) forms that we collect for tax reporting purposes.
2. Information about your transactions with us.
1. Information that relates to account balance, payment history, trading activity and any other such transactions for which Rockwell provides brokerage services.
2. Information we collect as part of authentication for purposes of servicing your account in a secure and confidential fashion; and
3. Information we collect through an Internet “cookie” (an information collecting device from a web server).
3. Information about your transactions with nonaffiliated third parties.
1. Information provided to other nonaffiliated third parties as required by law, including information shared in connection with a subpoena or other legal document compelling our compliance; and
2. Information related to servicing your account for purposes of providing clearing services.
4. Information from a consumer-reporting agency.
1. Information from a consumer reporting agency regarding your creditworthiness or credit history or other information with regard to lending;
2. Information about the fact that you are a customer of Rockwell and we have provided you a financial product or service; and
3. Information from other outside sources regarding their employment of, credit to, or other relationship with you, or verifying representations made by you, such as your employment history, loan or credit card balances.

NONPUBLIC PERSONAL INFORMATION DISCLOSED.

Rockwell will not disclose nonpublic personal information to affiliates or non-affiliated third parties, except as permitted by law, under the following circumstances:

1. Where we believe in good faith that disclosure is required under law to cooperate with regulators or law enforcement authorities.
2. To consumer reporting agencies.
3. To our clearing firm and service providers to help us process your applications or service your accounts.  These service providers, in turn, are required to protect the confidentiality and security of any information we give to them and may not reuse it for any other purpose. 

Rockwell restricts access to your personal account(s) and information to those employees who need to know that information to provide products or services to you.  We maintain physical, electronic and procedural safeguards that comply with the industry standards to safeguard your nonpublic personal information.  Third parties who have access to such personal information must agree to follow appropriate standards of security and confidentiality.  Clients should be advised that in order to better serve you, telephonic communications may be recorded and monitored for quality control.  
We trust this clarifies our position on client confidentiality, and look forward to being of service to you.