Introduction. We are committed to safeguarding your privacy. We believe that the best way to protect the privacy of users of our Sites is to tell you what information we gather and ensure that you understand and consent to Rothswell’s uses of information you provide.
Besides Personal Information, when you access or visit any of our Sites, we and our operational service providers and others who host our Sites may use technology that can recognize, collect, and transmit information that is associated with you, but which does not personally identify you. Although the term “cookies” specifically refers to small pieces of information that is stored by your browser on your computer’s hard-drive for record keeping purposes, we will use the term “cookie” to refer generically to any technology that can recognize, collect or transmit information about your visits to our Sites. “Cookie” information typically includes such data as your referring domain, type of internet browser, operating system software, screen resolution, date and time of visit and other technical data related to your visit. No personally identifiable information is collected by this process.
Cookies allow our Sites to recognize a users’ computer or access device each time it is used to visit our Sites and cookies can keep count of how often you return to our Sites. Cookies can also track how you use our Sites, the pages you visit and your preferences for features and functions. Most web browsers automatically accept cookies, but you can usually change your browser settings to prevent it from accepting cookies. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. We have sought to set up each Site so as to notify you before a cookie is used. However, if you choose to reject all cookies, you may be unable to use parts of our Sites.
How we use information collected. We use information collected or obtained when you use our Sites, including Personal Information, to ensure compliance with our Terms and Conditions and for our internal research purposes, such as to analyze trends, administer our Sites, track user movements on our Sites, gather aggregate demographic data about visitors so we can continually improve our Sites. In addition, we may also use your Personal Information for the purposes set out below if you have indicated that you wish us to use your Personal Information in this way when submitting such information:
- Market research;
- Responding to feedback;
- Informing you about our services which may include contacting you by telephone;
- Giving your information to affiliate offices which may be located outside the EEA to enable them to send you information which may be of interest to you or to contact you regarding your query;
- Sending you client bulletins or information that may be of interest to you.
Disclosure of Information to Third Parties. We always have the right to disclose your Personal Information to our operational service providers that we engage to assist us with our Sites such as hosting, storage fulfillment and disaster recovery. We always request that our operational service providers protect your privacy and not disclose your Personal Information to third party marketers that are not associated with our Sites, nor are our operational service providers allowed to use your Personal Information for their own marketing or promotional purposes.
We also reserve the right to make your Personal Information available:
- To other Rothswell offices;
- When compelled by a governmental agency, law, regulation, a court or other legal process;
- If we believe your use of our Sites has or may violate any law, regulation or our Terms and Conditions;
- If we believe you are or may be a threat to safety, security, property, interests or rights of us or others;
- In order to investigate or respond to or resolve problems or inquiries or defend our interests;
- In a merger, acquisition, change of control, joint venture or other business combination.
Save as described above, we do not otherwise disclose information about your individual visits to any Site or information which identifies you to any third parties unless we have your prior consent.
Opting-Out. We permit you to opt-in to receive certain communications from Rothswell. If at any time you want to opt-out of receiving communications from Rothswell or if you no longer wish your feedback to be displayed on any Site, please follow the unsubscribe or opt-out procedures contained in the communication or contact us at [email protected]. When contacting us, please provide your exact email address, name, postal address, and/or telephone number(s) in order to be sure we handle your request correctly.
Security. We take the security of your data seriously. Therefore, once we receive your transmission, we make our best efforts to ensure its security on our systems. The servers we store Personal Information in are kept in a secure physical environment. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it.
It is our policy to virus check documents and files before they are posted on any Site. However, we cannot guarantee that documents or files downloaded from any Site will be free from viruses and we do not accept any responsibility for any damage or loss caused by any virus. Accordingly, for your own protection, you must use virus-checking software when using our Sites. You must not post or provide to us via any Site, any document or file which you believe may contain a virus. You must virus check any document or file which you intend to post or provide to us via any Site.
Unfortunately no data transmission or security program can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. You remain responsible for the security of your computer at all times.
Your right regarding Personal Information. We aim to keep our information about you as accurate as possible and to use your Personal Information only as directed. If you would like to (i) review or change the information you have supplied us with or (ii) would like to be removed from our active marketing databases or (iii) would like us to stop using your Personal Information in the manner in which you approved, please contact us as set out below. If you ask us to remove your Personal Information, we reserve the right to retain as much of your Personal Information as is necessary to comply with legal, regulatory, internal audit and record-keeping requirements.
California privacy rights. If you are a resident of the State of California, under the California Civil Code, you have the right to request information on how to exercise your disclosure choice options from companies conducting business in California. To do so, send a request for information indicating your preference as to how you would like us to respond to your request (i.e., email or postal mail). To request such information, either send an email to our designated Privacy Administrator at [email protected] or contact us via postal mail, proper postage pre-paid, at:
Rothswell Financial Corporation
100 Park Avenue , Suite 1600
New York, NY 10017
Attn: Your California Privacy Rights
All requests sent via postal mail must be labeled “You California Privacy Rights” on the envelope or post card and clearly stated on the actual request. For all requests, please include your name, street address (if you would like a response via postal mail), city, state, and zip code. We will not accept requests via telephone or fax. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
Merger or other change. If Rothswell merges with, acquires or is sold to another firm or goes into bankruptcy or engages in other such business transactions, we may share files and email records, including your Personal Information, with our business and merger partners.
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