Rochester Investments, Inc., an independent Registered Investment Advisory firm, respects the privacy of any nonpublic, personal information that clients provide in order for us to open and service their accounts. We are committed to safeguarding that information by holding it in the strictest confidence.

We gather only information that is necessary for us to effect, administer, or enforce a transaction that a client authorizes or requests. Such information may include health and financial information that has been gathered from account applications and other forms needed to service accounts.

To further protect client privacy, we have policies in place to restrict employee access to personal information. We may disclose personal information to other financial institutions for the sole purpose of effecting a transaction requested or authorized by a client, or to service a product or to provide a service that a client has requested or authorized.

If a client transfers an account, in the process of transferring the account investments Rochester Investments may share information with the new broker/dealer or custodian. If a representative servicing an account leaves Rochester Investments to join another firm, the representative may retain copies of the information so that he or she can assist with the transfer of accounts and continue to serve clients at his or her new firm. Rochester Investments does not disclose information to nonaffiliated companies that intend to market their products.

Opting out of third-party disclosures: If clients do not want to share information (other than as prescribed by law) with nonaffiliated third parties, including the registered representative servicing their account when he or she is no longer a Rochester Investments Representative, clients should contact the Rochester Investments at 585-568-6656.

At times, federal and state regulators may also review firm records as permitted by law. We do not provide nonpublic, personal information to mailing list vendors or solicitors under any circumstances. Any information gathered will be maintained during the client’s tenure, and for the required time thereafter that records are required to be maintained by federal and state securities laws.

California Consumer Privacy Act  

The California Consumer Privacy Act of 2018 (“CCPA”) gives certain individuals (natural persons) who reside in the State of California certain rights to know what personal information we collect about them and how we collect, share, and protect their personal information. This information is set forth in “Information we Collect” and “Sharing Personal Information.” The CCPA also provides individual California residents with a right to opt-out of the sale of personal information, a right to request that a business disclose what personal information it holds about a consumer, and a right to request that a business delete their personal information. Certain individuals are and personal information is excluded from the coverage of the CCPA.

Regulatory Disclosures:

Information regarding the Securities Investor Protection Corporation (SIPC), including a SIPC brochure, can be obtained from the SIPC Web site at www.sipc.org, or by telephone at 202.371.8300.

Rochester Investments maintains a business continuity plan, including alternate processing facilities, to address disruptions in our normal course of business. These plans are reviewed annually and updated as necessary. In the event of a significant business interruption, information will be posted on the Rochester Investments public Web site (www.rochesterinvestments.com ), providing investors with alternate methods to contact us and conduct business.

The Rochester Investments can be reached at 585-568-6656 or in writing to Rochester Investments., Inc., 10 Office Parkway, Ste. 400, Rochester, NY 14534 regarding questions, concerns, or complaints.

The Financial Industry Regulatory Authority (FINRA) has published an investor brochure that describes its Public Disclosure Program. A copy may be obtained at www.finra.org.

©Rochester Investments, Inc. All Rights Reserved.
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