Online Privacy Notice
You take online privacy seriously, and so does the team at Rockview Digital Solutions, Inc., an Arkansas corporation doing business as Abaca (hereinafter, “Rockview Digital Solutions”). The terms “we,” “our,” and “us” in this Notice refer to Rockview Digital Solutions.
The purpose of this notice is to explain how we process or use your personal information, to help you understand why we collect, use, store, share, and secure your data, and to explain your privacy rights. This notice is addressed to people with whom we interact. This includes:
- visitors to our websites (our “Sites”);
- customers (including prospective customers, our customers’ advisors, family office staff or other associated professional advisors or consultants);
- people connected with the account holder as professional advisors, consultants, family office staff, directors, interns, secondees or officers;
- representatives of an account holder (such as holders of a power or attorney or other appointed third parties);
- anyone who calls our services centers or who writes to us via post, email or social media, and
- other recipients of our services (together, “you”).
This notice uses certain defined terms:
- “Personal data” is information that is about any individual, or from which any individual is identifiable. It can be anything from your name to your IP address. You can see what personal data we collect in section ‘What Personal Data we collect’.
- “Process, processed or processing” encompasses the collection, use, storage and analysis of data. The principle covers anything that is done with any personal data, whether or not by automated means.
In some cases, this will apply to the personal data of third parties.
This Notice applies only to those Rockview Digital Solutions interfaces that are a part of this site or link directly to it. It is important to know that our websites may contain links to third party sites not controlled by Rockview Digital Solutions or covered by this Notice. We recommend that you check the privacy statements of other sites you visit before providing any personal information.
Once you become a customer of Rockview Digital Solutions and/or our partners, we will provide you with a Consumer Privacy Notice that describes our privacy practices and provides you choices in the sharing of your information, as required by law.
How will we Update this Notice?
This notice may be amended and updated from time to time to reflect changes such as the categories of data that we collect, process and share or to reflect any changes in applicable law. We encourage you to regularly check this page, and we will include the effective date in order to help you check whether or not there have been any changes since you last accessed the notice.
What Should I do if I Have any Questions?
If you have any comments, questions or concerns that are not addressed in this notice, you can contact firstname.lastname@example.org.
- What personal Information we collect;
- How we use the Personal Information;
- How Personal Information is Shared;
- Information collected via Cookies;
- Your Legal Rights, Choices, and Disclosures
- Online Behavioral Advertising (OBA) on Third Party Sites;
- Storage and security of your Personal Information;
- Personal Information About Children;
- Public Forums Available On Our Sites and Social Media
- Reviewing and Changing Your Personal Information
- Questions and Contact Information
1. Personal Information We Collect
We collect personal and non-personal information when you provide it to us in the course of using our website. This table sets out the categories of personal data that we collect and generate. The type and amount of data that we collect and generate will differ depending on your relationship with us, and the services that we provide to you.
|Personal Information Collected, Generated, and Used
- Your name, including any previous names, preferred names or nicknames.
- Your gender, date of birth, nationality and marital status.
- Information concerning your identity, such as government issued tax identification numbers.
- Information about your lifestyle and social circumstances and details of your education and qualifications.
- Information relating to your personal appearance or behavior, such as how you interact with our services.
- Your address, telephone number, email address, and social media details.
- The nature of your industry and current role, plus any other business activities.
- The names of your current and former employers.
- Any contact details relating to your work.
- Your billing address and bank account numbers.
- our instruction records, transaction details, and counter-party details.
- Your total assets and overall financial position.
- The fact that you have a banking relationship with Abaca.
|View and Opinions
- Any views and opinions that you choose to send to us or make public.
- Any views and opinions about us that you choose to send to us or make public.
|Electronic Identifying Information
- IP addresses, geolocation data, online identifiers (including in relation to your device) and cookies.
- Information relating to your use of our sites, such as browsing activity or transaction logs.
|Personal Information of Third Parties
||Any of the above in relation to other parties such as family members, dependents, friends, employees and advisors.
2. How we use Personal Information
We use personal information collected online for various functions, which may include: processing your request for services, products or information improving our customer service and products servicing your account facilitating your participation in online activities.
For example, we may use the information you provide when you complete an online application for a product or service in order to process and evaluate your application. If you request product information, we may use the information you provide to mail you information you request.
We may also use the information you provide to contact you regarding your account and to process or collect payments. In addition, we may collect and use information for analytic purposes, market research or for marketing purposes, as allowed by law.
3. How Personal Information is Shared
We may share the personal information we collect about you with third parties, such as companies performing services on our behalf to provide the products or services you have requested. Some third parties who we share your information with process it in their own right and in accordance with their own privacy policies.
As permitted by law, we may also share information collected about you with companies with whom we have formal agreements to offer you financial products and services.
We may share information about you with our affiliates and partners, and with nonaffiliates for analysis, market research and marketing purposes as allowed by law.
We may also disclose your personal information as otherwise permitted or required by law.
Finally, you should be aware that once your data is shared with third parties they may also be under a legal or regulatory duty to share that information, in some cases by making that data public.
4. Information collected via Cookies
We use a variety of technologies, including cookies, to collect information about your online/mobile activity when you visit our website. Cookies are small text files that a website server stores on your computer or device. They’re typically used to remember your account login preferences, monitor website traffic, provide customer support like live chat and help us better customize our site for your individual preferences.
We may also use Flash® objects (sometimes called “Local Shared Objects”) as part of our online authentication to help us recognize your computer when you come back to our site. We do not use Flash objects for any online behavioral advertising purpose.
You can disable cookies by making the appropriate selection from your browser options to inform you when cookies are set or to prevent cookies from being set. However, if you choose to disable or delete cookies, you may limit the functionality we can provide when you visit our site.
5. Your Legal Rights, Choices, and Disclosures
This section is subject to specific disclosures on privacy rights set forth below. We are committed to facilitate the exercise of your rights granted by the laws of your jurisdiction, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale of your personal information (as applicable). We will do our best to honor your requests subject to any legal and contractual obligations.
You may have certain rights in relation to your data, and we want to make sure that you can exercise them. In some cases, however, we may not be able to continue to provide you with certain products and services or continue to operate your account. To exercise one or more of these rights, or to ask a question, please contact us.
||You have the right to request:
- confirmation on whether we possess or control copies of the personal data of which you are the data subject;
- copies of your personal data that we possess or control; and
- information about the ways in which such personal data has been or may have been used or disclosed within a year before the date of the request.
- To do so, you should submit a request by contacting us.
||If you believe that the personal data that we process or control is incomplete or inaccurate, you have the right to request rectification.
If you believe that the personal data is inaccurate, you have the right to ask us to restrict its processing while it is being verified.
||If we have asked for your consent in order to process your personal data, you have the right to withdraw that consent.
||You have the right to complain to the appropriate Data Protection Authority regarding the processing of your personal data, either by us or on our behalf.
Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority.
(a) European Union.
If you reside or otherwise find yourself in the territory of Europe, your privacy rights under the European data protection law include:
- Transparency and the right to information. Through this policy we explain how we use and share your information. However, if you have questions or need additional information you can contact us any time.
- Right of access, restriction of processing, erasure. You may contact us to request information about the personal data we have collected from you and to request the correction, modification or deletion of such personal information, which requests we will do our best to honor subject to any legal and contractual obligations.
- Right to withdraw your consent at any time. When we process your personal data based on your consent, you have the right to withdraw it at any time.
- Right to object at any time. You have the right to object to the processing of your personal data based on your specific situation. We will assess your request and provide a reply in a timely manner according to our legal and contractual obligations.
- Right to data portability. You have the right to data portability of your own personal data by contacting us.
- Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your personal data that may negatively impact you.
- Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal data infringes your privacy rights according the European Privacy regulation, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement.
California “Shine the Light” Information-Sharing Disclosure. California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed. If you are a California resident and want such a list, please send us a written request by email to email@example.com with “California Shine The Light Rights” in the subject line.
California Do Not Track Disclosure. We do not respond to Web browser “Do Not Track” signals at this time. To prevent Rockview Digital Solutions or third parties from tracking, you can access your browser settings and disable or delete your cookies.
California Consumer Privacy Act Disclosures. Under the California Consumer Privacy Act
(CCPA), California residents have the right to request:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information is collected;
- The business or commercial purpose of collecting or selling personal information;
- The categories of third parties with whom we share or sell personal information;
- The categories of personal information about you that we have sold; and
- The specific pieces of personal information we have collected about you.
Additionally, you have the right to request deletion of your personal information, the right to opt out of the sale of your information (if applicable) and the right not to be discriminated against for exercising any of your CCPA rights.
(c) Social Security Numbers
Rockview Digital Solutions collects Social Security numbers as necessary to support state and federal legal requirements, to provide products or services to you and to meet needs within our Human Resources unit. To support these requirements, we restrict the access to Social Security numbers only to employees, agents, service providers, and government entities that require access to Social Security numbers to meet these purposes.
We strive to protect Social Security numbers from unlawful disclosure and keep them confidential by maintaining administrative, technical, and physical safeguards that comply with applicable state and federal regulations.
6. Online Behavioral Advertising (OBA) on Third Party Sites
There are three ways we use OBA on third party websites and mobile apps that are not affiliated with Rockview Digital Solutions.
(a) Interest–Based Advertising
(b) Device-Based Advertising
We also use device information, particularly in mobile advertising, to help deliver our ads and measure ad campaign effectiveness. Rockview Digital Solutions, Inc. and the companies we work with won’t collect any personally identifiable information (PII) but may collect your device information when you visit one of our sites or see our ads.
Compiling and comparing this information creates a unique ID for individual devices and can be “matched” to the same information on other sites or mobile applications. Some companies we work with are also able to associate related devices into households based on common characteristics, such as IP addresses.
7. Storage and Security Of Your Personal Information
We consider protecting the security of your personal information as very important. We restrict access to the personal information obtained from our website to only those employees, agents and contractors who need it to do their jobs. We maintain administrative, technical, and physical safeguards designed to protect your personal information.
Additionally, companies that provide online services on our behalf are required by contract to protect customer information. They are only allowed to use the information they collect for the purpose of providing the services that we have contracted to them.
8. Personal Information About Children
We do not knowingly collect or maintain personal information about children under the age of 13 unless the personal information is provided by a parent, legal guardian or authorized adult. Our websites are not intended for children under 13. Visit the Federal Trade Commission website for more information on the Children’s Online Privacy Protection Act (COPPA).
9. Public Forums Available On Our Sites And Social Media
Public forums are available on our sites, and they may include text, photographs and videos that are accessible to the general public. Unless we tell you otherwise, any information you disclose in these areas may become public information.
You should use caution when deciding to disclose personal information in these areas.
10. Reviewing and Changing Your Personal Information
You may obtain a copy of and request that we correct errors in your personal information by emailing us at firstname.lastname@example.org. If you do desire to obtain a copy of your personal information, you will be required to provide proof of your identity. If your personal information changes or if you no longer want to subscribe to or use our services, you may correct, update or deactivate your personal information and your account through the account management screen.
You may also select the “Contact Us” link – usually found in the navigation menu – or log into your Abaca account and select Account Information to edit your personal information and select My Profile to edit your personal information.
This Notice is effective September 30, 2019. We reserve the right to alter this Notice at our discretion. Any change to this Notice will be posted on our sites in a timely manner.
12. Questions and Contact Information