Our Privacy Policy is designed to provide information on our privacy practices and notices. When you interact with Rochester Investments as an individual investor, or through services provided by us to your employer, it is important that you understand how we use and care for your personal information.

Privacy Notices

Notices applicable to you may differ depending on where you reside, or who is your primary custodian. Your custodian may have additional Privacy Policy and provide additional Privacy Notices directly to you. In the event of material changes to our Privacy Policy, we will post the most up to date policy on this page with a new “Last Updated” date. Changes to our Privacy Notices will become effective when posted unless indicated otherwise. We are here to answer your questions.

The Rochester Investments Corporate Privacy Notice – https://rochesterinvestments.com/rochester-investments-corporate-privacy-notice/

Personal Information We Collect

Personal Information is information which uniquely identifies you, such as your name, email address, banking information, or other data that can be reasonably linked to you. We collect Personal Information to help us service your accounts.

The kind of information we collect depends on your interactions with us, the products and services you apply for and what we need to maintain your accounts. Additionally, some service custodians may share your information with us for specific purposes, such as to verify your identity and to protect your accounts and financial information.

Information you provide to us.

You may provide Personal Information to us through our website and applications. For example, you may register to use our services or create an account with us, which allows or requires you to provide certain information to us (e.g., contact information such as your name, email address, telephone number, date of birth, income information etc.). You provide Personal Information and other information to us when you contact us through our websites, by phone, email, or text message (with your consent, where required by law). We may also collect Personal Information from you when you subscribe to our newsletters and other subscriptions and to participate in surveys about our services.

Information we collect from other sources.

We may collect Personal Information from third parties such as consumer reporting agencies to assess your creditworthiness, or other providers for identity verification services, etc.

Information we collect automatically as you use our website.

We have access to information about your devices, browsers, and Internet activity as you use and interact with our website. The information we have access to includes unique identifiers, browser types and settings, device types and settings, operating systems, mobile network information including carrier name and phone number, and application version numbers. We also have access to information about the interaction of your browsers and devices with our websites, such as IP address, device type, system activity, wireless carrier name (when you use a wireless or mobile device), and the date, time, and referrer URL of your request.

Our website, and online services may store or retrieve information on or about your browser, mostly in the form of small files called cookies and similar technologies (together, “cookies”). Cookies ensure our website works as intended and enable us to personalize and capture your preferences, measure the effectiveness of advertisements and web searches, and improve your experience with our services.

Our cookies are organized into the following categories:

  • Necessary Cookies 
    Necessary cookies are usually set when you take a specific action, such as logging in, setting your privacy preferences.
  • Functional Cookies 
    These cookies help us personalize our website and enhance how it functions. Functional cookies can be set by us or by a third-party provider servicing our website.
  • Analytical Cookies 
    These cookies help us track how our website performs, such as counting visits, traffic sources, and other data points. Analytical cookies help us learn which pages perform best, which ones need work, and how visitors like you navigate the website. The information from these cookies is analyzed at an aggregate level.
  • Marketing Cookies
    We work with advertising partners to optimize our digital marketing. These cookies do not capture details like your name or email address. We may use information from marketing cookies to measure the performance of our digital marketing. The information also may be used to show you relevant advertisements on other websites.

To disable cookies, adjust the settings on your browser (e.g., Chrome, Edge, Safari). Disabling cookies may modify your experience on or ability to navigate our websites.

How We Respond to Opt-out Preference Signals
Some browsers incorporate opt-out preference settings such as “Do Not Track (DNT)” or “Global Privacy Control (GPC)”. These settings, when turned on, are intended to send a signal or preference to websites you visit indicating you do not wish to be tracked. We do not respond to such signals, except for those we detect from California-based IP addresses. Also, some U.S. states and jurisdictions, including California, have laws that provide you with additional means of limiting our use of such information. Please refer to relevant jurisdictional notices for more information.

Opting Out of Interest Based Advertising
At this time we don’t use third-party online advertising companies, but if we do in the future will update this policy as such.

How We Use and Share Your Personal Information

We use Personal Information for various functions, such as to:

  • Process transactions at your request for services, products, or information.
  • Maintain and service your account(s).
  • Improve our services. We may contact you about our services as well as those offered by third parties that may be of interest to you.
  • Facilitate your participation in online activities. We may use your contact information to communicate and interact with you, such as to send you emails and text messages about financial products and services. We use the IP address provided by your device to send you the data you request to display on your device.
  • Comply with legal and regulatory obligations.
  • Maintain the safety, security, and integrity of our business.

We share information about you:

  • With custodians.
  • With trusted service providers who support and help develop our services. Our service providers are contractually committed to our standards for safeguarding your information.
  • To protect the rights, property, or safety of our firm, our customers, or others. This may include exchanging information with other companies and organizations for fraud protection and credit risk reduction.
  • To comply with legal and regulatory obligations, including cooperation with law enforcement, judicial orders, subpoenas, and regulatory inquiries.
  • Text message/SMS consent will not be shared with any third party and affiliates for marketing, nor will any phone numbers for SMS purposes.
     

Personal Information about Children

Our website is not intended for children under 13 years of age. We do not knowingly collect Personal Information from children under 13 unless the Personal Information is provided by a parent, legal guardian, or authorized adult. If you believe we might have any information directly from a child under 13, please contact us using the Contact us page of our website.

Please also visit the Federal Trade Commission website for more information on the Children’s Online Privacy Protection Act (COPPA). 

How We Safeguard Your Personal Information

To protect your Personal Information from unauthorized access and use, we use security measures that comply with federal law. To learn more about security, please visit https://www.sec.gov/securities-topics/cybersecurity.

Contact Information and Manage Preferences

If you would like to opt out or manage your preferences with respect to receiving advertising and marketing communications from us, or if you have any questions, concerns, complaints, or suggestions regarding any of our Privacy Notices or the ways in which we collect and use your Personal Information, have any requests related to your Personal Information pursuant to applicable laws, or otherwise need to contact us, please check your Schwab statement for the most direct number at which to reach us. In some instances, specific contact information may be included on the Privacy Notice that applies to you or use the Contact us page of our website.

Last Updated November 19, 2024

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