Privacy Policy

Last Updated: June 11, 2021

ROX Financial LP and its affiliates, series and subsidiaries (“ROX”) respects the privacy of our website visitors. This privacy policy (the “Policy”) describes the type of information we may collect from you or that you may provide when you visit the website www.roxfinancial.com and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Policy does not apply to information collected by us offline or through any other means, including on any other website operated by us or any third party or through any application or content (including advertising) that may link to or be accessible from our website.  

 

This Policy applies to personally identifying information provided by or otherwise collected from website visitors. This Policy does not apply to personally identifying information that website visitors provide to a business partner or third party, even if such business partner or third party is linked to our website.

 

When you use this site, you agree to this Policy. If you do not agree with this Policy or our Terms of Service, you should immediately cease use of our website.

 

Our website is intended for users in the United States only. The servers that make our website available are located in the United States. If you are a non-resident of the United States, do not use this website or provide us with any of your personal information. California users of this site should review the “Additional Information for California Residents” section below.

 

Information We Collect

 

Other than your IP address (explained below), we do not collect personally identifying information from users unless they provide it to us voluntarily. When you choose to contact us (e.g., by email or an online contact form) or request email alerts or other information, we will receive information that can personally identify you. We do not share any information with anyone outside ROX, except as otherwise specified in this Policy.

 

The types of information we may collect include, among other things, your:

  • Name;

  • email address;

  • phone number; and

  • mailing address or postal code.

 

In addition, when you visit our site, your browser automatically sends us an IP (Internet Protocol) address and certain other information, including the type of browser you use and browser and standard web server log information. We may use this IP address and other information to give you access to the site and otherwise administer the site. However, at this time, we do not send this information to third parties except as it pertains to Google Analytics (as explained below).

 

Cookies

 

We may use cookies – small data files stored on the computer or device you use – that record your preferences. We may store cookies on your computer’s hard drive when you use our website. Cookies help us make sure that our websites work, and work efficiently, and help us understand website traffic. They help us speed up your future activities or improve your experience by remembering the information that you have already provided to us. Cookies may also help us enforce our Terms of Service and maintain website security. In addition, you may get cookies from third parties that have a link on our websites, but we have no control over these cookies. These third-party cookies do not fall under our Policy. Most likely, your web browser has a setting that allows you to modify your preferences so that you can decline cookies. However, if you select this setting you may be unable to access certain parts of the websites. Please see https://www.allaboutcookies.org/cookies/ for more information on cookies. Our websites do not currently respond to web browser “do not track” signals.

 

Web Beacons

 

Pages of our websites may contain web beacons, which are small electronic files that permit us to  collect certain usage information about our site, such as the number and frequency of visitors to certain parts of the websites. This data is used only in the aggregate and does not include any personally identifying information. Web beacons also help us collect other website statistics that help us better understand the functionality and popularity of our website and its content.

 

Google Analytics

 

We use Google Analytics to collect information on your use of our websites. Google Analytics is a service that anonymously collects website traffic data through cookies. The data, which includes geolocation data, is not tied to other personal information we collect about you and helps us analyze and review how our website visitors use our websites. The anonymous data is sent to, and stored by, Google on servers that are housed in the United States, but the data is not sent to any other third parties. If Google is required to by law, it may transmit the anonymous data to a third party. To know more about the data collected by Google Analytics, visit https://www.google.com/policies/privacy/.

 

Visitor Provided Information

 

In certain parts of the site, we may ask you to provide us with certain personal information (including your name or other information) so that we can provide you with information you request or take other action indicated in the part of the site where the personal information is requested. You are under no obligation to provide us with this information, but, without it, we may not be able to take the action requested. The site also includes features that allow you and us to communicate by electronic mail, text message, or otherwise.

 

If you choose to use these features, you will be required to provide us your e-mail address and other personally identifying information (such as your name, phone number, or postal address) we may deem necessary to communicate with you electronically, by text message or otherwise, or review your request. When you provide any personally identifying information to us, you acknowledge that you are voluntarily providing us such information. We may respond to the electronic mail messages you send us, take other action indicated in the part of the site where the information is requested, and use such information for any other business purpose, including sending you subsequent communications concerning this site or ROX.

 

How We Use and Disclose the Information Collected

We may use or disclose the information provided to us for the following business purposes:

  • To present our websites and their contents to you;

  • To allow you to participate in the interactive features on our websites;

  • To fulfill or meet the reason(s) for which you provided the information (e.g., to respond to your email or request for information);

  • In any other way as described to you when you provide information, including in order to communicate with you about our business or to provide you with information or marketing materials that may be of interest to you;

  • In the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation involving ROX or our business, we may transfer, sell, or assign to third parties information collected from you;

  • If permitted or required by law, court order, or government regulation;

  • To help maintain the safety, security, and integrity of our websites, products and services, databases and other technology assets, and business, or where we believe such action is necessary in order to protect or defend our interests or the interests of our customers or users of our websites;

  • If necessary in the unlikely event of an emergency, to protect us, our agents, our website visitors, or the public as required by law, or in a situation in which public authorities are required to deal with an emergency situation;

  • To determine your geographic location; and

  • For any other purpose disclosed by us when you provide the information or with your consent.

 

What Information We Share

 

We will not share, sell, rent, trade, or otherwise disclose your personally identifying information you provide to anyone outside of ROX except as expressly provided in this Policy. Please be aware, however, that it may be possible for others to read messages that you send over the Internet, so do not send by e-mail, or post online, any information that you would like to keep confidential.

 

If we disclose personally identifying information to a third party for a business purpose, such as to administer our site, manage our email communications, or deliver information requested by you, we enter into a contract that describes the purpose and requires the recipient of such information both to keep such information confidential and to refrain from using such information for any purpose except performing the contract.

 

Other Information You Submit

 

If you use the communication features of this site to provide us with information other than personally identifying information, including to offer suggestions about the site, product and advertising ideas, and any other such information, that information will belong to us and may be used, reproduced, modified, distributed and disclosed by us in any manner we choose, without attribution or paying compensation to you, to the extent allowed by law.

 

Children Under 13

Our website is not intended for use by children under 13 years of age. We neither market our website to children under the age of 13 nor knowingly collect personally identifying information from children under 13. Website visitors who are under the age of 13 should not use our websites and may not provide us with any personally identifying information. If we learn that we have collected or received personally identifying information regarding a child under the age of 13, we will delete such information.

 

Links

 

Our website may contain links that take users to other websites. In no case is personally identifiable information or cookies provided to the third-party sites. We are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.

 

Changes to Privacy Policy

 

We reserve the right, at our sole discretion, to change this Policy at any time by posting revised terms on the site. It is your responsibility to check periodically for any changes we may make to this Policy. Your continued use of this site following the posting of changes to these terms or other policies indicates that you accept the changes. If material changes are made to how we treat our visitors’ personally identifying information, we will put a notice on the website. The date that the Policy was last revised will also be identified at the top of the Policy.

 

How to Contact Us

 

If you have any questions or concerns about this Policy or the collection of information, please contact us by e-mail at legal@roxfinancial.com.

 

Miscellaneous

 

This Policy as stated herein constitutes the entire agreement between you and ROX with respect to ROX’s privacy practices. No changes to the Policy shall be made except by a revised posting on this page, and you are responsible to be aware of all such changes.

 

This Policy shall be governed by and construed in accordance with the laws of the State of Delaware applicable therein, without regard to conflict of laws. You irrevocably consent to the exclusive jurisdiction of the courts located in the State of Delaware in connection with any action arising out of or related to these terms of use or their subject matter. You waive any objection based on lack of personal jurisdiction, place of residence, improper venue or forum non-conveniens in any such action.

 

If any court having competent jurisdiction holds any provision of this Policy invalid or unenforceable in any respect, such provision shall be enforced to the maximum extent permitted by law, and the remaining provisions of this Policy shall continue in full force and effect. No waiver of any provision of this Policy shall be deemed a further or continuing waiver of such provision or any other provision of this Policy.

 

Additional Information for California Users

 

Shine the Light Law.

 

California Civil Code Section 1798.83 allows our California resident website users to request certain information regarding our disclosure of personally identifying information to third parties for their direct marketing purposes, if any. To make such a request, please contact us by e-mail at legal@roxfinancial.com.

 

California Consumer Privacy Act Disclosure.

 

This additional disclosure explains how ROX collects, uses, and discloses personal information relating to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”) (for more information on the CCPA, please visit https://oag.ca.gov/privacy/ccpa). This disclosure and notice is provided pursuant to the CCPA.  These rights are not absolute and are subject to certain exceptions more fully set forth in the CCPA. 

 

Introduction

 

Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular California resident. The specific Personal Information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based on our relationship or interaction with that individual. For more information about how we generally collect, disclose, and secure information relating to our customers, please refer to our Policy above.

 

Keeping Personal Information secure is one of our most important priorities. Consistent with our obligations under applicable laws and regulations, we maintain appropriate safeguards that are designed to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, or access, whether it is processed by us or elsewhere.

 

Collection and Disclosure of Personal Information

 

We launched this website in June of , 2021.  Since the launch of this website, we have collected, and disclosed to third parties for our business purposes, the following categories of Personal Information:

  • Personal information, as defined in the CCPA, such as contact information; and

  • Internet or other network activity information, such as browsing history, search history, and interactions with our website.

 

The categories of sources from whom we collected this Personal Information are:

  • Directly from a California resident or the individual’s legal representatives;

  • Service Providers and other third parties;

  • Information from our affiliates; and

  • Website.

 

The categories of third parties to whom we disclosed Personal Information for our business purposes described in this CCPA privacy disclosure are:

  • ROX (including its respective sires, subsidiaries thereof, affiliates);

  • Service Providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure, customer service, email delivery, marketing and marketing research activities; and

  • Government agencies as required by applicable laws and regulations.

 

Use of Personal Information

 

Since the launch of this website, we have used Personal Information relating to California residents to operate and manage our business, to provide our products and services, and to accomplish our business purposes and objectives, complying with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance, codes or opinions).

 

Do Not Sell My Personal Information/Notice of Right to Opt Out

 

Under the CCPA, the “sale” of your Personal Information means the sharing of your personal information with certain third parties. Under the CCPA, consumers have the right to direct a business that sells Personal Information about the consumer to third parties not to sell the consumer’s Personal Information. Currently, we do not share your Personal Information in a manner that would be considered a sale under CCPA. Further, we disclose your Personal Information to our Service Providers pursuant to contracts that prohibit the Service Provider from using your personal information for any purpose other than those services specified in the contract.

 

Rights under the CCPA


If you are a California resident, you have the right to:

  • Request we disclose to you free of charge the following information covering the 12 months preceding your request:

    • the categories of Personal Information about you that we collected;

    • the categories of sources from which the Personal Information was collected;

    • the purpose for collecting Personal Information about you;

    • the categories of third parties to whom we disclosed Personal Information about you and the categories of Personal Information that was disclosed (if applicable) and the purpose for disclosing the Personal Information about you; and

    • the specific pieces of Personal Information we collected about you.

  • Request we delete Personal Information we collected from you, unless the CCPA recognizes an exception; and

  • Be free from unlawful discrimination for exercising your rights under the CCPA.

 

You have the right, at any time, to direct us not to sell your Personal Information. We will acknowledge receipt of your request and advise you how long we expect it will take to respond if we are able to verify your identity. Requests for specific pieces of Personal Information will require additional information to verify your identity. If you submit a request on behalf of another person, we may require proof of authorization and verification of identity directly from the person for whom you are submitting a request. In some instances, we may not be able to honor your request. For example, we will not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. Additionally, we will not honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer or where the Personal Information that we maintain about you is not subject to the CCPA’s access or deletion rights. We will advise you in our response if we are not able to honor your request. We will not provide social security numbers, driver’s license numbers or government issued identification numbers, account passwords or security questions and answers, or any specific pieces of information if the disclosure presents the possibility of unauthorized access that could result in identity theft or fraud or unreasonable risk to data or systems and network security. We will work to process all verified requests within 45 days pursuant to the CCPA. If we need an extension for up to an additional 45 days in order to process your request, we will provide you with an explanation for the delay.

 

If you are a California resident, you may submit an opt-out request by emailing legal@roxfinancial.com. You may contact us with questions or concerns about this Disclosure and our practices by emailing legal@roxfinancial.com.

 

We may change or update this Disclosure from time to time. When we do, we will post the revised Disclosure on this page with a new “Last Updated” date.