PRIVACY POLICY

Your privacy is important to us. This Online Privacy Policy explains how we collect, share, use and protect your personal information when you visit or use this and other online services offered by RP Holdings that link to or reference this policy (collectively, our “online services”). Please note, however, that this Online Privacy Policy is not an exclusive statement of our privacy principles across all products and services. Other privacy principles or policies may apply depending on the financial products or services you obtain from us, or the jurisdiction in which we are doing business with you. You can access many of these policies using the links at the bottom of this page.

We take our responsibility to protect the privacy and confidentiality of your information, including personal information, very seriously. We maintain physical, electronic and procedural safeguards that comply with applicable legal standards to secure such information from unauthorized access and use, alteration and destruction. We hold our employees accountable for complying with relevant policies, procedures, rules and regulations concerning the privacy and confidentiality of information.

The types of personal information we may collect from you when you visit or use our online services include your name, email address, mailing address, telephone number(s), account numbers, limited location information (for example, a zip code to help you find a RP Holdings office near you), user name and password. We may also collect payment card information, Social Security numbers, driver’s license numbers (or comparable) when you provide such information while using our online services and where we believe it is reasonably required for ordinary business purposes.

In addition to the personal information described above, we may collect certain information about your use of our online services. For example, we may capture the IP address of the device you use to connect to the online service, the type of operating system and browser you use, and information about the site you came from, the parts of our online service you access, and the site you visit next. As explained in more detail in our Cookies Policy, we or our third-party partners may use cookies (as well as web beacons or other technologies) to collect and store this and other information about your visit to, or use of, our online services. We may later associate the usage and other information we collect online with personal information about you, as permitted or required by law.

We may also collect information about you from additional online and offline sources including commercially available third-party sources, such as credit reporting agencies. We may combine this information with the personal and other information we have collected about you under this Online Privacy Policy.

We may use the information we collect from you to help us deliver our online services; to administer, evaluate and improve our business (including developing new products and services, improving existing products and services, performing data analytics, and performing accounting, auditing and other internal functions); manage our risks; market our services and products; and to comply with and enforce applicable laws and regulations, relevant industry standards, contractual obligations and our policies. We may also use data that we collect on an aggregate or anonymous basis (such that it does not identify any individual clients) for various business purposes, where permissible under applicable laws and regulations.

For your convenience, RP Holdings offers you the ability to access some of our products and services through mobile applications and mobile-optimized websites. When you interact with us through your mobile device, we may collect information such as unique device identifiers, your screen resolution and other device settings, information about your location, and analytical information about how you use your mobile device. We may ask your permission before collecting certain information, such as precise geolocation information.

We share personal information among our affiliates and business units when we believe it will enhance the services we can provide, but only in circumstances where such sharing conforms to law, any applicable confidentiality agreements, and our policies and practices.

We may disclose information we have about you as required or permitted by law. For example, we may share information with regulatory authorities and law enforcement officials when we believe in good faith that such disclosure is necessary to comply with legal requirements. We may share information with third parties where appropriate to protect against fraud or verify or enforce our terms of use, our other rights, or other applicable policies.

From time to time, we enter into agreements with other companies to provide services to us, or to make services and products available to you. Under these agreements, these companies may receive your personal information, but they must safeguard this information, and they may only use it for those purposes we specify.

We may transmit, transfer or process information to, or through, any country in the world, as we deem necessary, appropriate or consistent with legal or regulatory obligations.

We may give you choices regarding the sharing of personal information with affiliates and third parties. Choices you have about the sharing of your personal information will be described in the privacy policies or notices you receive in connection with the financial products or services you obtain from us.

Keeping your account information up-to-date is very important. You may review or update certain account information by logging in and accessing the “Client Center” section. If you cannot change the incorrect information online, or you prefer to request changes offline, please contact your RP Holdings representative using the contact information listed on your account statements, records or other account materials.

We respect your decisions about the collection of personal information related to your online activities over time and across different websites for advertising purposes.

RP Holdings does not allow unaffiliated third parties to collect personal information about your online activities when you visit our online services. Nor do we use personal information collected across non-affiliated websites for the purpose of serving you advertising related to your browsing behavior. If we engage in this practice in the future, we will provide appropriate notice and choice so that you may opt out of the practice.