This Privacy Notice describes the privacy policy of Rossmore Private Capital, LLC.

Our Commitment to You

When you become a Rossmore client, you entrust us not only with the management of your assets, but also with personal and financial information about you. We recognize that your relationship with us is based on trust and that you expect us to act responsibly and in your best interest. Because we have access to this private information about you, we work hard to respect the privacy of this information. Rossmore’s Privacy Policy applies to current and former clients of Rossmore.

The Information We Collect About You

In the course of doing business with you, we collect nonpublic personal information about you. “Nonpublic personal information” is personally identifiable private information about you. This information may include: (i) your name, address and telephone numbers; (ii) your employment information, including salary and benefits; (iii) information relating to your financial situation, such as your income, assets, liabilities and debts; and (iv) information about your portfolio assets and transactions, as well as brokerage and custody arrangements for your portfolio.

How We Handle Your Personal Information

We will not disclose any nonpublic personal information about you to non-affiliated parties, except as allowed by you as necessary to service your portfolio or as required by law. We and our service providers will use your nonpublic personal information primarily to complete transactions or portfolio changes that are requested or authorized by you. In the normal course of serving you, information that is collected may be shared with companies that perform various services for us or for you (e.g. custodians). The companies that receive client information will receive only the information that we believe to be necessary to carry out their assigned responsibilities. Such companies are authorized to use your information only for the services required and are not permitted to share or use your information for any other purpose.

In addition, generally we will share nonpublic personal information about you if any of the following are satisfied: (i) the other party is an affiliate of Rossmore and does not use that information to market its services to you; (ii) the other party provides services for you and we have a written contract with the other party that obligates the other party to keep such information confidential and to use such information only for the purposes designated or referred to in the contract; or (iii) you consent to the disclosure.

We also may disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required or permitted by law (for example, to cooperate with regulators or law enforcement authorities, such as responding to a subpoena or other legal process, or to protect portfolios from fraud) or to resolve client disputes.

We do not sell client information to any person for any reason.

How We Safeguard Your Personal Information

We maintain physical, electronic and procedural safeguards to protect the confidentiality of all nonpublic personal information we have about you. In particular, we restrict access to nonpublic personal information about you to only those persons who need it to provide services to you or who are permitted by law to receive it.

We’ll Keep You Informed

We reserve the right to modify the Privacy Policy at any time, and we will notify you of any material changes made to the Privacy Policy.

Should you have any questions regarding this Privacy Notice or our Privacy Policy, please contact Brian Sheehan at (860) 200-6090.