Richmond Capital Advisors LLC (RCA) Privacy Policy
Policy Effective Date: June 1, 2024
Your Privacy Matters
RCA's number one priority is your trust. Your privacy is essential to earning and keeping that trust. This tenet drives all of the decisions we make, as well as how we gather, use and store any information we acquire from you.
We created this Privacy Policy to be as clear and direct as possible about how we gather and use your non-public personal information and other types of personal information (“Personal Information”) and to assist you in exercising your privacy rights.
Introduction
Richmond Capital Advisors LLC (“RCA”, “we”, “us” and/or “our”) currently offer portfolio management services, and may offer additional products and services in the future (collectively, the “Services”), through RCA's website, www.richmondcapital.com (“Site”). This Privacy Policy describes how RCA treats your Personal Information when you use our Site or Services.
For the purpose of this Privacy Policy, a “User” is a party who creates an account on our Site to understand or evaluate our Services; and a “Client” is a party (including a User) who signs one of our Client Agreement for any reason, including to engage in portfolio management services.
Our Privacy Policy, Website Terms of Use and Client Agreements, govern different aspects of your use of our Site and Services.
Information Collection
The categories of information we collect from Users differs from what we collect from those who qualify as Clients. Examples of instances when we collect Personal Information include:
when you answer questions on the Site to determine what kind of portfolio we might recommend if you were to become a Client, when you register to open an account either as a User or a Client, when you contact our client service organization with questions, or when you agree to enter one of our Client Agreements.
Wherever RCA collects Personal Information, we endeavor to provide a link to this Privacy Policy and other relevant terms.
Information We Collect from Users and Clients
We collect Personal Information from Users and Clients, including but not limited to:
name, e-mail address, telephone number, zip code, Internet Protocol address, birth date; investable assets, income information, and other financial planning information about your household; and account numbers, routing numbers, and login credentials for the financial accounts you choose to link to our Services, any challenge and/or security questions associated with those linked accounts, and any information contained in those linked accounts. (Note: The section labeled “Information We Collect When Acting As Your Authorized Agent” provides additional details regarding how we use and protect this information.) Additional Information We Collect from Clients Only
In addition to the information described above, Clients provide us additional Personal Information, including but not limited to:
your full legal name, contact information, birth date, Social Security Number, citizenship, and marital status; the full legal name, birth date, and Social Security Number of any beneficiaries that Clients choose to list; for purposes of identity verification, government-issued identification documents and self-portrait photographs (“selfie”); and investment objectives, approximate net worth, tax information, and other information required by federal and industry laws and regulations, such as employment information and stock restrictions (see our Client Agreements). You are not required to provide these items to us to become a User, but Users who choose not to provide these items to us will not be able to become Clients.
Other means by which we collect Personal Information include the following:
Automatic Data Collection. When you use our Services, we may collect your Internet protocol (“IP”) address; cookie identifiers; mobile carrier, mobile advertising and other unique identifiers; details about your browser, operating system or device; location information; Internet service provider information; pages that you visit before, during and after using the Services; information about the links you click; and other information about how you use the Services. Information we collect may be associated with accounts and other devices. Anonymized or Aggregated Information. RCA's Site record certain anonymized or aggregated information about your use or evaluation of our Services. Anonymized or aggregated information is used for a variety of purposes, including the measurement of Users' and Clients' interest in and use of various portions or features of the Site. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including for internal analysis and research. We may share this information with third parties for our purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you. Cookies and Pixels. Similar to other consumer internet services, RCA uses cookies, a small piece of computer code that enables our Web servers to identify Users and Clients, each time an individual initiates a session on our Site. A cookie is set in order to identify you and tailor the Site to you. Cookies do not store any of the Personal Information that you provided to us; they are simply identifiers. You may delete cookie files from your hard drive at any time through your browser settings. However, cookies may be necessary to provide access to much of the content and many of the features of the Site. Pixel Tags. Along with cookies, we may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow us to monitor the use of our Site. A pixel tag can collect information such as the IP address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server. Site Activity. RCA may also use third-party tracking technology, such as Google Analytics, to record your activity on our Site. “Do Not Track” Technology. We do not collect Personal Information about your online activities over time and across different websites or online services. Therefore, our Site does not respond to Do Not Track (“DNT”) signals. We do not knowingly authorize third parties to collect Personal Information about your online activities over time and across different websites or online services. Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information. How we use Information No Renting, Selling or Trading Out List
We will never rent, sell or trade your Personal Information to anyone. Ever.
User Personal Information
We utilize the Personal Information of our Users for a variety of business purposes, such as to help our Users evaluate our Services, offer new products and services, enhance our Services, and for research and internal analysis.
Client Personal Information
RCA stores, processes, and maintains Personal Information of our Clients for a variety of business reasons such as to provide client support, analyze and improve our Services, offer new products and services, and provide our Services to Clients in accordance with the rules of regulatory authorities..
Identity Verification for Clients
We may use third-party vendors for identity verification. These vendors analyze whether the Client's “selfie” matches the government-issued identity document. The information collected from Client photographs may constitute biometric information in some jurisdictions. Where required by law, we will seek consent from you prior to any such collection. We require our third-party vendors who support identity verification to agree to destroy any potential biometric data that is created or gathered for purposes of verifying your identity no more than ninety (90) days after its collection.
Cross-Device Tracking
Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your computer. To do this, we may analyze your browsing patterns, geo-location and device identifiers to match the information of the browser and devices that appear to be used by the same person.
Social Media and Links to Other Websites and Applications
This Privacy Policy and these terms apply only to RCA-operated Services and applications. Please note that our Site may for your convenience contain links to other websites, applications, social media accounts, and information that are not operated by RCA. RCA does not control these linked third-party websites or their privacy practices, which may differ from those set out in this Privacy Policy. Any Personal Information you choose to provide to linked third parties is not covered by this Privacy Policy. We encourage you to review the privacy policy of each company or website before submitting any Personal Information. Some third parties may choose to share their users' Personal Information with us; that sharing is governed by that company's privacy policy, not this Privacy Policy.
Mobile Computing
RCA provides websites and online resources that are specifically designed to be compatible for use with mobile computing devices. Mobile versions of our Site are governed by the provisions hereunder related to the Site and may require that you log in with an account. In such cases, information about the use of each mobile version of the website may be associated with your accounts. In addition, we may enable individuals to download tools, such as an application, widget or other tool, that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to RCA to enable you to access your account information and to enable us to track the use of these tools. Some of these tools may enable users to e-mail reports and other information from the tool. We may use Personal Information or non-identifiable information transmitted to us to enhance these tools, to develop new tools, for quality improvement, and as otherwise described in this Privacy Policy or in other notices we provide.
General
You have choices regarding the use and disclosure of your Personal Information, as set out in this Privacy Policy.
You may decline to provide Personal Information to RCA. Declining to provide Personal Information may disqualify you from using RCA Services, the Site and other features that require certain Personal Information.
Before we use Personal Information for any new purpose we will provide information regarding the new purpose.
Email and Telephone Communications.
RCA may use your Personal Information to communicate with you regarding our Services or to tell you about blog posts or Services that we believe will be of interest to you.
Other Important Information
Security
RCA takes reasonable steps, endeavoring to use appropriate technical or organizational measures, to protect your Personal Information from loss, misuse, unauthorized access, alteration, disclosure, or destruction. However, no Internet, email, or electronic operating system that enables the transmission of data is ever fully secure or error-free; therefore, we cannot ensure or warrant the security of any information you transmit to us.
Federal Privacy Laws
Please be aware that certain federal privacy laws govern the collection and record keeping of nonpublic Personal Information collected by RCA, and state privacy laws may be inapplicable in certain situations related to such Personal Information.
Notice to California Residents
To the extent not covered by the federal privacy regulations noted above, California residents may have the following rights with respect to data collected by RCA.
California law permits Users and Clients who are residents of California to request and obtain from us once a year, free of charge, a list of the third-parties to whom we have disclosed their Personal Information (if any) for those third-parties' direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Please note that this disclosure requirement only applies if we share Personal Information with third parties for those third parties to directly market their own products to those consumers, and RCA does not share Personal Information with third parties for those third parties to directly market their own products to Users or Clients.
Under the California Consumer Privacy Act (CCPA) Users who are California residents may request and obtain from us twice a year, free of charge, information related to Personal Information we have collected in the 12 months preceding the request.
As noted above in the “Retention and Deletion” section, Users may also request the deletion of Personal Information RCA has collected. Because of separate collection and record keeping requirements imposed on RCA, deletion requests by those who qualify as Clients generally cannot be accommodated.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time as we deem necessary at our sole discretion. If there are material changes to this Privacy Policy, we will notify you as required by applicable law.
RCA encourages you to review this Privacy Policy periodically to be informed regarding how we are using and protecting your information and to be aware of any policy changes. Your continued relationship with RCA after the posting or notice of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Policy will take effect immediately after being posted or otherwise provided to you by us. Each version of this Privacy Policy will be identified on this page by its effective date.
This document constitutes RCA's complete Privacy Policy for RCA and its Services and Site.