Effective January 1, 2025

1. Information we collect

What types of information we gather from you depends on the product or Services you have with us.  This information may include:

• Your name, contact information, home/business address, driver’s license number and social security number;
• Your date of birth, gender, and marital status;
• Your log-in information when you log into our (or our affiliate’s) platform;
• Business ownership information, including profit sharing and ownership interests; 
• Your financial information, including without limitation, your net worth and your bank statements and tax returns. 
• If you use our (or our affiliate’s) platform, we may also collect information about the browser you are using.  This information can include:

• Your IP address or other device identifying information, browser type, browser language, the date and time of your request;
• One or more cookies that may uniquely identify your device; and 
• Information obtained through the use of cookies, flash cookies, web beacons, embedded script, or other similar tracking technologies.

We may supplement this information with data from third parties.  This information may include:

• Information from other sources, such as financial records, employment history, background information (including, without limitation, criminal background/history), medical records, or other third-party data; and
• Information from other reporting agencies, state and federal government agencies such as state motor vehicle departments, and credit reporting agencies (including credit reports/history/scores).

We treat all information about you, whether received from you or from a third-party, in accordance with this Privacy Policy and our Terms and Conditions (contained herein).

2. How do we use the information we collect?

We use the information we collect to provide, maintain, protect, optimize and improve our Services, and to enhance your user experience.  We may also use the information we collect in the following ways:

Regular Business Purposes

We use the information you provide to update your account(s), process or Service requested or authorized transactions, respond to your inquiries and requests, send you notifications, send administrative information to you such as changes to our terms, conditions, and policies, and verify your identity.

For Our Own Analytic Purposes

Roc Capital may also use your information to develop new Services, conduct research, and create anonymous or aggregated reporting for its (or its affiliates’) own use.

For Our Own Marketing Purposes

Roc Capital may use your information to offer our Services to you.

To Comply with Legal Requirements

It may be necessary to provide information collected from you to respond to subpoenas, other discovery requests, legal investigations, court orders or to otherwise comply with the law.  We may share information pursuant to a governmental agency or investigatory body request. Roc Capital may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. 

Other Business or Commercial Purposes

We may use your information for other business or commercial purposes, as permitted by law, including but not limited to, such purposes as:

Data analysis

Operating and expanding our business activities

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.

Audits, including reviewing current interactions with you and related transactions,

As part of a Merger/Acquisition/Bankruptcy or other transaction.

3. How is your information shared?

Roc Capital does not share, sell, rent or otherwise distribute your personal information except:

With Our Service Providers

We may share your personal information with other companies and individuals to perform functions or services for us or on our behalf, such as hosting this Site, sending email messages, making phone calls, and processing requests for background and credit checks.  These parties are contractually or otherwise restricted from using any personal information for purposes other than providing services for Roc Capital (or its affiliates) or on our behalf.

For Administrative and Legal Reasons

See Section 2 above.  Additionally, Roc Capital® also reserves the right to disclose or use information if it has a good faith belief that such action is necessary to:  (a) protect and defend the rights, property or liability of Roc Capital® or its affiliates, other users of this platform, or the public; (b) enforce the Terms and Conditions; (c) respond to claims that any content violates the rights of third-parties; (d) respond to claims of suspected or actual illegal activity; (e) detect, address or prevent fraud, security or technical issues; or (f) respond to an audit.

With Business Partners

We may disclose personal and other sensitive information, as necessary, in connection with providing our products and Services.  In order service our loan products/related products, we may disclose your information to loan buyers, financing providers, insurers, reinsurers, insurance intermediaries, brokers, lenders, underwriters, insurance reference bureaus, medical service providers, fraud detection agencies, our other advisers, lawyers, accountants, and other third parties involved in the servicing process(es).

With Your Consent

We may disclose personal and other sensitive information after receiving your consent for such disclosure. Such consent may be provided via written, electronic, or verbal means, subject to Roc Capital’s ability to reasonably validate your identity and determine the authenticity of such request. 

For Joint Marketing Purposes

We may share or disclose your information to third parties with whom we have a contractual relationship for joint marketing purposes.  These third parties are contractually restricted from using any personal information for purposes other than the joint marketing arrangement that is the subject of the contractual relationship.  Additionally, we do not share or disclose your information with third parties for the third parties’ own direct marketing purposes outside of a joint marketing arrangement with us.

SMS Consent

We may collect your phone number if you choose to provide it through our website or other means. SMS consent is not shared with third parties or affiliates for marketing purposes. Your SMS consent is used solely for communications directly from Roc Capital (the “Brand”).

4. How can you limit the sharing of your data?

Roc Capital respects your privacy and your right to limit the sharing of your information.  The following identifies ways in which you can limit the sharing of your information and data:

• You can contact us at any time to limit our sharing by using the contact information at the bottom of this Privacy Policy.  Please note, however, that federal law gives you the right to limit only:
  • Sharing for affiliates’ everyday business purposes;
  • Affiliates from using your information to market to you; and
  • Sharing for non-affiliates to market to you.
• State laws may give you additional rights to limit sharing.
• You can also opt out of receiving marketing emails by following the opt out instructions in any marketing email or text message you receive.
• If you do not wish to allow our website to use cookies or similar tracking tools, you may configure your browser to block them.  Please understand that blocking cookies may reduce the functions and Services our website makes available to you.

For more information on how to reject or delete cookies, you should consult with your browser’s or device’s help documentation or visit www.aboutcookies.org.  At this time, Roc Capital does not (a) respond to automated signals regarding tracking mechanisms, including “do not track” instructions from your browser; or (b) allow third parties to install software to track users’ identities on its website.

To limit the use and disclosure of your personal information, please submit a request to info@roccapital.com.

5. What steps does Roc Capital®  take to protect your information?

Secure Internet Connectivity.  Roc Capital® protects your personal/private information through the use of encryption technology.  We use industry standard security protocol (Secure Sockets Layer or “SSL”) to ensure that the connection between your browser and our server remains protected.  Unfortunately, no data transmitted over the Internet or data storage system can be guaranteed 100% secure.  If you believe your connection with us is no longer secure for any reason, please notify us immediately. 

Information Security.  Personal information and user-specific settings and preferences are stored using commercially standard database and website security software.  User passwords and other sensitive user information are saved in encrypted form to prevent unauthorized access or disclosure and accidental loss, alteration, or destruction. 

Evaluation of Information Protection Practices.  Periodically, our operations and business practices are reviewed for compliance with corporate policies and procedures governing the security, confidentiality, and quality of our information.

Employee Access, Training and Expectations.  Our employees are required to protect confidential third party information in general as a condition of employment at Roc Capital (or its affiliates), and our business practices limit the use and disclosure of such information, including personal information, to authorized persons, processes, and transactions.

6. Additional concerns

Updating and Correcting Your Information

Keeping your information accurate and up to date is very important since inaccurate or incomplete information could impact our ability to deliver Services to you.  Please let us know about any changes that may be required to your personal information emailing us at info@roc capital.com 

Continued Use of Information

Even if you are no longer our customer or client, we may continue to share your information as described in this Privacy Policy.

External Links and Third-Party Privacy Policies

Roc Capital may post links to third-party websites that are governed by their own terms and are not subject to this Privacy Policy.  We do not exercise control over these third-party sites and are not responsible for the privacy practices of any third-party.  We encourage you to read the privacy policies and terms of use of any third-party web sites you visit.

International Users

Children

The Services are not intended for anyone under the age of 18.  We do not knowingly collect, use or disclose information of children under the age of 18 without the consent of their parents or legal guardians.  We will delete any personal information collected that we determine to be from a user younger than the age of 18.

Rights of California Residents

If you are a California Resident/Consumer, you may have certain rights with respect to your personal information under the California Consumer Privacy Act of 2018 (CCPA). For additional information on our data collection practices, your rights under the CCPA, and how to exercise those rights, you can visit our California Privacy Statement by visiting this link.

In addition, Roc Capital does not share or disclose your personal information to third parties for the third-parties’ direct marketing purposes, except with respect to third parties that are affiliated companies or with whom we have a contractual relationship.

Communications

For additional information, or if you have questions regarding this Privacy Policy or privacy practices at Roc Capital, please send correspondence to info@roccapital.com or via postal mail to:

Roc Capital LLC

645 Madison Avenue, 19th Floor

New York, NY 10022

Changes to Privacy Policy