The Roosevelt Investment Group, LLC (“we”, “us”), collects, uses, and shares personal data to provide services and products to its customers and in connection with its business operations. This notice is designed to help you understand what information we collect and how we use it.

Categories of Information We May Collect

In the normal course of business, we may collect nonpublic personal information about you, including the following types of information:

• Information you provide in an investment management agreement and other forms (such as name, address, social security number, date of birth, income, and other financial-related information).
• Data about your securities transactions (such as the types of investments you have made and your account status).
• Data about your interactions with us (such as through account or information inquiries via mail, email, website, or telephone).
• Information we obtain through account opening documents and custodial statements.

How We Use and Share Your Information

We use your information to provide you with financial products and services, and for our own internal business purposes.

We share your nonpublic personal information in the following ways:

• We may share our clients’ nonpublic personal information with our staff and nonaffiliated third parties which are service providers to us. Our service providers include our accountants, attorneys, consultants and vendors.
• If you have given us permission, we may share information with anyone you designate, such as your relatives or service providers (such as an attorney or accountant).
• We may share client information with entities or people who referred clients to us, and pursuant to a joint marketing agreement.
• We may disclose nonpublic personal information as required by law (such as to respond to a subpoena) or to satisfy a request from a regulator and/or to prevent fraud. Without limiting the foregoing, we may disclose nonpublic personal information to governmental entities and others in connection with meeting our obligations to prevent money laundering including, without limitation, disclosure that may be required by the Uniting and Strengthening America Act by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001 and the regulations promulgated thereunder.

We do not share your nonpublic personal information with unaffiliated third parties to market their goods and services to you.

Confidentiality and Security

We restrict access to our clients’ nonpublic personal information to employees and agents who need to know that information to provide products and services to us and our clients. We maintain reasonable physical, electronic, and procedural safeguards to protect our clients’ nonpublic personal information.

If we dispose of clients’ nonpublic personal information that we are not legally bound to maintain, we will do so in a manner that reasonably protects such information from unauthorized access. The same policy also applies to former clients.

Online Privacy and Cookie Policy

We collect information from users of our website including through the use of cookies.

Information we collect about users of our website and social media sites

We collect personal information about users through our website and our webpages on social media sites such as LinkedIn, which may include the following:

• Information users provide when they enter information on our website, such as when submitting a “Contact Us” message (such as name and email address);
• Information users provide when requesting literature such as applications or prospectuses (such as name, address, phone number, and email address);
• Information users provide when posting content on social media sites;
• Information users provide in their social media bio;
• Information captured in our web logs such as device information (e.g. device brand and model, screen dimensions), unique identification numbers (e.g. IP address and device ID), and browser information (e.g. URL, browser type, pages visited, date/time of access); and
• Information captured by cookies (see section on “Cookies and how we use them” below).

To learn how we use and share this information, please see the sections titled “How We Use and Share Your Information,” “Cookies and how we use them,” and “Website analytics and online tracking”.

Cookies and how we use them

This website uses cookies to improve your browsing experience while you navigate through the website. A cookie is a small text file which includes a unique identifier that is sent by a web server to the browser on your computer, mobile phone or any other internet enabled device when you visit an online site. Cookies and similar technologies are widely used to make websites work efficiently and to collect information about your online preferences.

Ways that we use cookies and other tracking technologies include:

• To assist you in navigation;
• To analyze your use of our products, services or applications;
• To assist you with our promotional and marketing efforts;
• To maintain and enhance our website and the services and information we offer; and
• To analyze trends in our users’ behavior.

Website analytics and online tracking

We may share aggregated anonymous data concerning our users as collected through our website with certain third-party analytic services such as Google Analytics to better understand your use of our website and our services. Google Analytics collects information such as how often users visit the websites, what pages they visit and what other sites they used prior to visiting. Google uses the data collected to track and examine the use of the websites, to prepare reports on its activities and share them with other Google services. Google may use the data collected on the websites to contextualize and personalize the ads of its own advertising network. Google’s ability to use and share information collected by Google Analytics about your visits to the websites is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. Google offers an opt-out mechanism for Google Analytics here: “http://tools.google.com/dlpage/gaoptout.”

You can change your privacy preferences regarding the use of cookies and similar technologies through your browser. Useful information about the technical aspects of cookies can be found at http://www.allaboutcookies.org.

As a general rule, we do not permit any third parties (such as advertisers) to install cookies on our websites or engage in behavioral advertising. However, our site contains links to other websites operated by third parties, including social media websites, such as LinkedIn. These third-party websites may collect information about you if you click on the link and may automatically record information about your browsing behavior every time you visit a website that has a social media button or link. Your interactions with these features are governed by the privacy policy of the company providing the feature, not by our online privacy policy. We do not control what information these third parties collect.

Policy changes

We reserve the right to change or update this Online Privacy Policy at any time without prior notice. We are committed to conducting business in accordance with these guiding principles in order to ensure the confidentiality of your personal information is protected and maintained.

Contact

If you have any questions regarding this privacy notice, please contact Steven Weiss at 646-452-6700 or by mail at 570 Lexington Avenue, Suite 1800, New York, NY 10022.

Last updated: February 25, 2021