California Privacy Statement

This California Privacy Statement is for California Residents only and supplements the Privacy Policy. This policy describes the personal information that Roc Capital (“we,” “our,” or “us”) collects in the course of its business, explains how this information is collected, used, shared, and disclosed, describes rights provided by the California Consumer Privacy Act of 2018 (“CCPA”) to California Residents (“consumers” or “you”) regarding their personal information, and explains how consumers can exercise those rights.

The CCPA does not apply to certain personal information, including, for example:

  • Personal information covered under certain federal or state financial privacy laws, including but not limited to the Fair Credit Reporting Act. For more information, please visit SITE LINK to view our privacy notice.
  • Personal information you provide us when acting in other capacities, such as a job applicant, employee, independent contractor, or as a representative of another business (such as a service provider, vendor, or other entity that we do business with). For more information on your rights under the CCPA when acting in other capacities, please contact us at (212) 607- 8333

Personal Information We Collect, Use, Share, or Disclose

The CCPA requires us to disclose certain information regarding our collection, use, sharing, and disclosure of personal information.

Personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“Personal Information”). “Personal information” does not include: (1) publicly available information, such as information that is lawfully made available from federal, state, or local records, and (2) de-identified or aggregate consumer information.

Collecting Your Personal Information

In the past 12 months, we have collected the following categories of Personal Information:

  • Identifiers.  This may include a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
  • Personal information described in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)).  This category is similar to Identifiers and includes a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
  • Characteristics of Protected Classification under California or Federal Law.  This may include age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
  • Commercial information.  This may include business ownership information and records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Internet or other similar network activity.  This may include browsing history, search history, or information on a consumer’s interaction with a website, application, or advertisement, such as your clicks and how long you are using our website.
  • Professional or employment-related information.  This may include current or past job history or performance evaluations.
  • Inferences drawn from other Personal Information. This may include information, data, assumptions, or conclusions derived from facts, evidence, or another source of information or data reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.


In the past 12 months, we have collected Personal Information from the following categories of sources: 

  • Public Records
  • Opt In Advertising Networks
Using Your Personal Information

We may collect your Personal Information for the following business or commercial purposes:

  • Account Services, including: (1) establishing, maintaining, supporting, and servicing an account you may have opened with us and for which you provided the information or that you may have applied for or established with us; (2) providing services, products, or information you may have requested from us; and (3) performing services such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, or providing similar services on our own behalf or on our service provider’s behalf.
  • Security and Fraud Detection, including detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity.
  • Debugging, including identifying and correcting errors to our system and services.
  • Improvement of Products and Services, such as enhancing the quality of our products and services.
  • Internal Research, including technological development and demonstration.
  • Advertising and Marketing Services, including advertising or marketing services on our own behalf or on behalf of our affiliates.
  • To Comply with our Legal Obligations.
  • Audits, including reviewing current interactions with you and related transactions.
  • As part of a Merger/Acquisition/Bankruptcy or Other Transaction.
  • For Other Business or Commercial Purposes, as permitted by law.
Sharing or Disclosing Your Personal Information for a Business or Commercial Purpose

We may share or disclose your Personal Information to service providers and third parties in order to carry out specific business or commercial purposes. In the preceding 12 months, we have disclosed the following categories of personal information to service providers and the following categories of third parties:

  • Identifiers to advertising networks, operating systems and platforms, social networks, and data brokers
  • Personal information described in the California Customer Records Statute to advertising networks, customer relationship management platforms, social networks, analytics platforms, retained marketing agencies, and data brokers
  • Characteristics of Protected Classification under California or Federal Law – Not Applicable
  • Commercial information – Not Applicable
  • Internet or other similar network activity to advertising networks and social networks
  • Professional or employment-related information – Not Applicable
  • Inferences drawn from other Personal Information to advertising and social networks


In the preceding twelve (12) months, we have not sold any personal information. In addition, we do not sell personal information. Also, it is our business practice not to sell personal information of minors under 16 years of age and we have no actual knowledge of doing so.

Your Rights under the CCPA

As described in more detail below, the CCPA provides you with certain rights regarding the collection, use, sale, and disclosure of your Personal Information. As we noted above, because Roc Capital does not sell personal information, we have not included a description of the right to opt out of the sale of personal information. If you have any questions regarding our sharing practices, please e-mail us at
The Right to Know About Personal Information Collected, Used, Sold, Shared, or Disclosed

You have the right to request that we provide you with certain information about the Personal Information we collect, use, sell, share, or disclose about you as well as the categories and specific pieces of information that we have collected about you in the 12 months before you submit a request, including:

  • The specific pieces of Personal Information we have about you.
  • The categories of Personal Information we have collected about you, including:
    • The categories of Personal Information we have collected about you in the past 12 months.
    • The categories of sources from which the Personal Information about you was collected.
    • Our business or commercial purpose for collecting your Personal Information.
    • If we shared your Personal Information: 
      • The categories of Personal Information that we disclosed about you for a business purpose in the past 12 months and, for each category identified, the categories of third parties to which we disclosed that particular category of Personal Information; and
      • The categories of third parties that we share Personal Information.
    •  If we sold your Personal Information, which we do not do: 
      • Our business or commercial purpose for selling your Personal Information.
      • The categories of your Personal Information that we have sold about you in the past 12 months and, for each category identified, the categories of third parties to which we sold that particular category of Personal Information. 

However, there is certain information that we will not disclose to you.  This information includes but is not limited to your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answer, or unique biometric data generated from measurements or technical analysis of human characteristics.

The Right to Request Deletion of Personal Information

You have the right to request that we delete any Personal Information that we have collected from you and maintained about you. Once we receive and confirm your request, if we determine that we must comply with a deletion request and delete your Personal Information from our records, we will also direct any service providers we work with to also delete your Personal Information from their records.  If we store any of your Personal Information in our archived or back-up systems, we will delete your information once the systems are accessed, restored, and/or used.

Please note that we may deny your deletion request for a number of different reasons, which are identified in the CCPA. 

The Right to Nondiscrimination
We will not discriminate against you for exercising any of your CCPA rights. For example, unless otherwise permitted by the CCPA, we will not:
    • Deny you goods or services.
    • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
    • Provide you with a different level or quality of goods or services.
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your Rights under the CCPA

Request to Know or Request to Delete Personal Information
Submitting a Request to Know or Request to Delete Personal Information

To exercise your Right to Know or your Right to Delete Personal Information, please submit a request to us by either:
Calling us at (212) 607-8333
To submit a request, you (or your authorized agent) will be asked to:
Send email request to
Only you (or an authorized agent) may make a request. You may also make a request on behalf of your minor child.
Once we receive your request, we will confirm our receipt of your request within 10 business days and provide you with additional information about how we will process the request.

Verifying Your Identity

Once you submit your request, we will verify your identity by matching the information you provided us with information in our systems.

If you submit a request to know specific pieces of Personal Information or a request to delete certain information, in addition to verifying your identity with information we have on file, you also may be required to submit a signed declaration under penalty of perjury stating that the requestor is the consumer whose Personal Information is the subject of the request.  If we are unable to respond to your request for specific pieces of information, we will evaluate your request as if it is a request to know the categories of Personal Information that we have collected about you.

We will try to avoid requesting additional information from you to verify you.  If we cannot verify your identity based on the information we currently maintain, however, we may request additional information from you, which will only be used to verify your identity and for security or fraud-prevention purposes.  We will delete any new Personal Information we collect to verify your identity as soon as practical after processing your request unless otherwise required by the CCPA.

Generally, if we are unable to verify your identity, we will deny your request and send you a letter explaining why we were unable to verify your identity.

Please note that we are only required to respond to your request for access to your Personal Information twice within a 12-month period.

Responding to Your Request to Know or Delete
Our goal is to respond to your request within 45 calendar days of receiving the request, beginning on the day we receive the request. However, in the event that we need more time (up to 90 calendar days) to respond to your request, we will provide you with a notice explaining the reasons that we will take more than 45 calendar days to respond. Any disclosures we provide will cover the 12-month period preceding the date we received your request.
Authorized Agent for Requests

You may designate an authorized agent to make a request on your behalf. Unless you have a power of attorney, if you would like to use an authorized agent, which is an individual or business registered with the Secretary of State that you have authorized to act on your behalf, to submit a request, you must provide the authorized agent with signed permission to do so, and verify your own identity directly with us or directly confirm that you provided the authorized agent with permission to submit the request. We may deny a request from an authorized agent that does not submit proof that they are authorized to act on your behalf.

Changes to Our California Privacy Statement

We are required by law to update this California Privacy Statement at least once each year.  This California Privacy Statement was last updated on December 31, 2021.

Contact Information

If you have any questions regarding our privacy policies, our California Privacy Statement, the ways in which we collect, use, disclose, and sell your Personal Information, or how to exercise your rights under the CCPA, please do not hesitate to contact us at:


Phone: (212) 697-8333
Roc Capital

645 Madison Avenue, 19th Floor 

New York, NY 11022