At Rosenthal Collins Group, L.L.C. (“RCG”) we value our customers, and maintaining customer trust and confidence is our highest priority. While it is necessary that we obtain accurate and current information about our customers in order to provide the highest level of customer service, we are dedicated to protecting the privacy and confidentiality of our customers’ information.
RCG collects your personal information whenever you use our services or when you use our website. RCG will never sell your personal information to anyone. We promise that we will uphold the privacy policies and procedures as set forth below.
2. INFORMATION WE COLLECT ABOUT OUR CUSTOMERS
The personal information we collect from you comes from information you supply to us voluntarily, either when visiting our website or in account opening applications (whether written or electronic), or in other forms you may provide to us, or from a broker you have chosen to use.
This information may include:
- your name;
- your address;
- your social security number or tax identification number;
- financial information about you;
- information regarding your transactions with us, including your trading history at RCG, your history of meeting margin calls or your use of the various services and products that we provide; and
- information about your credit history and information we may receive from your introducing broker or associated person and other consumer reporting agencies.
3. WHY WE COLLECT YOUR INFORMATION
We use your personal information to conduct our business and to provide you with the best possible services and experience.
We also use your personal information to:
- provide the services you have asked us to provide;
- verify your identity;
- submit your daily and monthly statements to you;
- process your futures trades and generate futures trading statements;
- determine if you have sufficient risk capital to trade futures;
- communicate with you about the services you have asked us to provide;
- provide you with marketing and offers from us (where we have your permission to do so if you are a resident of the European Economic Area (“EEA”);
- improve our services; and
- comply with our security obligations.
4. INFORMATION WE MAY SHARE ABOUT OUR CUSTOMERS
RCG will not sell personal information regarding our current or former customers.
RCG may share personal information about our current and former customers with our affiliated companies and service providers around the world. In either case, your personal information will remain subject to strict confidentiality protections.
To the extent that we may engage unaffiliated companies to assist in providing services such providers will be subject to contractual requirements to maintain the confidentiality of any personal information they may obtain in connection with the performance of their services for us. Such service providers will only be allowed to use personal information in the course of providing services to RCG and only for the purposes that we authorize.
We may also disclose your personal information to a third party when you ask us to do so or when we believe it is required by law.
5. INFORMATION WE MAY DISCLOSE
We may disclose information about current or former customers in order to cooperate with legal or regulatory authorities or pursuant to a court order or subpoena.
We may also disclose personal information as necessary to perform credit checks, collect debts, enforce our legal rights or otherwise protect our interests and property.
6. RETENTION OF YOUR INFORMATION
We will only retain your personal information for as long as it is necessary to provide our services to you and where you have asked us to do so and/or to provide you with the best customer experience possible, and as required by law. This type of processing is necessary for the purposes of our legitimate interests (for example, to deal with any claims or queries which you have relating to our services), or where we are required to do so by law.
7. RCG IS COMMITTED TO PROTECTION OF YOUR PERSONAL INFORMATION AND TO PROTECTING YOUR PRIVACY
Only authorized RCG employees, agents or service providers will have access to your personal information. Each of them is held to the highest standards of privacy and security.
We shall implement appropriate technical and organizational measures to ensure a level of security appropriate to potential risks, which may include:
- the pseudonymisation and encryption of your personal information where appropriate;
- ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services;
- ensuring we can restore access to personal information in a timely manner if a physical or technical incident occurs; and
- regular testing, assessment and evaluation of the effectiveness of our technical and organizational measures to ensure your personal information is secure.
We maintain physical, electronic and procedural safeguards to protect the confidentiality and security of personal information transmitted to us.
8. COOKIES AND OTHER SIMILAR TECHNOLOGIES
Our website uses “cookies”, which we use to distinguish you from other visitors, track your IP address and usage of our site and to indemnify the name of the website from which you linked to our website. This information is used to help us serve you better by improving our website design, as well as our products and services. We do not otherwise track any information about your use of other websites. Non-personal information or anonymized/pseudonymised information obtained through cookies may be obtained by or shared with service providers on our behalf.
You can disable cookies at any time by using your browser options; however, if you turn off cookies, we will not be able to recognize you as a registered user to allow you access to your account information.
9. THIRD PARTY WEBSITES
Our website, products and services are all directed to people who are at least 13 years old or older. If you are under 13, do not use or provide any information on this website or on or through any of its features/register on the website, make any purchases through the website or provide any information about yourself to us, including your name, address, telephone number or email address. RCG does not knowingly collect personal information from a child and will delete it if it becomes aware that it has been provided.
If you believe that children have provided RCG with personal information please contact us immediately at firstname.lastname@example.org.
11. BUSINESS TRANSITIONS
We pride ourselves on excellent customer service, but if you would like to make a complaint about the way we have collected or used your personal information, please contact us at email@example.com.
13. CHANGES IN POLICY
14. EEA RESIDENTS ONLY
As we may process information from EEA residents we have to comply with the Data Protection Act no 2472/1999, Law no 3471/200, and from 25 May 2018 the General Data Protection Regulation (EU) 2016/679, when keeping personal data about you when we obtain, use, disclose or otherwise process such data. Any personal information processed by RCG is controlled by us. As such we are considered the data controller of your personal information.
We do not store your personal information in the EEA. Our servers-storing and keeping your information secure-are located in the United States.
Collecting your information legally
We are able to legally collect and use your personal information either because:
- you have provided us with your consent to do so as explained above;
- collecting and using your personal information is necessary for us to carry out our legitimate business interests in order to carry out any requests or orders made by you via our website;
- collecting and using your personal information is necessary for the performance of a contract to which you are a party; and/or
- collecting and using your personal information is necessary for compliance with a legal obligation.
You have the right to:
- obtain confirmation from us that your personal information is being collected and used by us and to access the personal information held about you by us;
- have your personal information corrected if it is inaccurate or incomplete at any time;
- erasure, or the right to be forgotten, which means you can request deletion or removal of any personal information we hold about you at any time, and we will accommodate your request to the extent permitted by U.S. law;
- block or suppress us collecting and using your personal information, which means we can continue to store your personal information but we cannot further collect or use it in any way;
- obtain and reuse any personal information we hold about you for your own purposes across different services, which allows you to move, copy or transfer your personal information easily from RCG to another place notified by you to us in a safe and secure way without hindrance to the usability of your personal information; and
- object to us collecting or using your personal information where this is based on:
– a legitimate interest or the performance of a task in the public interest; or
– direct marketing.
To make any requests as listed above, please contact us at GDPR@rcgdirect.com.
We will confirm any requests relating to your rights above within one month of receipt of your request, or within two months of receipt of your request where your request is more complex.
Withdrawal of consent
We will ask for your consent to use your personal information to provide marketing information to you. If you do not give us your consent, or you withdraw your consent, we will honor that request. You can also tell us to stop collecting and using your personal information at any time by emailing us at GDPR@rcgdirect.com. However, if you do so we will most likely be unable to continue to service your account.
Update your information sharing preferences
To update us with your information-sharing preferences, you may contact us at GDPR@rcgdirect.com.
If you are an EEA resident and you are unhappy about the way we have handled your complaint and/or you would like to take the matter further, you may make a complaint directly to a UK regulator without contacting us first.
RCG has also retained a GDPR representative who is located in the UK. The representative is Achieved Compliance Advocacy Ltd. and they can be reached at rcg@GDPRrepresentative.eu.