The Caprock Group, LLC, and its affiliates (“Caprock”) are committed to safeguarding Personal Information (“Personal Information”) and processing Personal Information in line with applicable privacy and data protection laws.
This privacy notice (“Privacy Notice” or “Notice”) describes how Caprock collects and processes Personal Information in the course of conducting business, visiting our website, or applying for employment with us, and describes rights residents of certain states may have with respect to their Personal Information. It does not apply to information we collect about individuals when acting in their capacity as employees or independent contractors.
This Privacy Notice applies to information we collect when you access or use our website, www.caprock.com (the “Website”) We may provide different or additional notices of our privacy practices with respect to job applications or other products and services, in which case this Privacy Notice will not apply.
Caprock is committed to processing personal information (“Personal Information”) in line with all applicable privacy and data protection laws. References to “you” or “your” refers to individuals whose Personal Information is collected or processed by Caprock, including clients with direct or indirect relationships (such as those who invest through an intermediary); employees, contingent workers, officers, agents (together “Representatives”); and beneficial owners of an organization or entity in connection with:
- the provision of services to potential and actual clients;
- transactions to which we are party (including those which we effect on behalf of clients); or
- services provided to us by a third-party vendor.
This Privacy Notice sets out the purposes for which we collect, use and Personal Information and how it is protected. It also sets out individuals’ rights in relation to the processing of their Personal Information.
There may be additional terms, conditions and commitments that also govern how we collect, use and disclose your Personal Information, which should be read in conjunction with this Privacy Notice.
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular client or household, including nonpublic personal information that Caprock obtains in connection with providing a service or financial product to such client such as information regarding a client’s account balance and investment activity.
Personal Information We Collect
Purposes for Collection of Personal Information
We use the Personal Information we collect to provide services to our customers, to manage and administer their holdings. This includes analyzing and processing applications and redemptions, servicing accounts, processing transactions, maintaining investor accounts and communicating with the client about their holdings and account-related activities on an ongoing basis. This also includes marketing to existing and prospective customers, to help us with information security and fraud detection, and to maintain our relationships and fulfill our obligations to our clients.
In addition, we also may use Personal Information to process a job application and evaluate people as a potential hires. We can use Personal Information to enforce or defend the legal rights of Caprock, a Caprock client or another third party. Caprock will collect and use Personal Information in the course of business for tasks such as, the execution of account documents, and to enable Caprock to comply with its legal and regulatory obligations.
We may use Personal Information to contact someone to notify them of services offered Caprock which we believe may be of interest (except to people who advise us that they do not wish to receive marketing or market research communications from Caprock).
Caprock will retain Personal Information for as long as required. We will retain Personal Information only for as long as is functionally necessary and appropriate. Caprock complies with applicable regulatory obligations regarding data retention. We delete Personal Information once there is no longer any legal or regulatory requirement or legitimate business purpose for retaining that Personal Information.
Disclosure of Personal Information For Business Purposes
Caprock may disclose the Personal Information we collect to third party service providers, governmental authorities, or to other third parties including other financial institutions as directed by the customer or otherwise required or permitted by law for multiple purposes, including:
- Maintaining client records and providing centralized administrative and marketing services for current and prospective clients;
- Monitoring of electronic communications and other systems security and/or regulatory reasons;
- Completing account documents, and processing transactions and investments;
- For recruiting and applicant evaluation purposes ; and
- For other legal and regulatory obligations including reporting tax information to tax authorities and compliance with AML regulations.
The provision of Personal Information by a client may be necessary for Caprock to provide clients with the requested services, for the performance of any contractual relationship with that client, to comply with any legal or regulatory obligations and for the other purposes as set out in the Privacy Notice. Caprock does not disclose any Personal Information it collects about its client or former clients to anyone other than to its affiliates and certain service providers in connection with the administration, processing and servicing of client accounts or to its accountants, attorneys and auditors; as otherwise permitted or required by law, such as to respond to court orders and legal investigations or report to credit bureaus; or in the case of a merger, acquisition by another company, or sale of all or part of Caprock’s assets or during due diligence associated with a contemplated transaction. Caprock does not share Personal Information with unrelated third parties for those third parties’ own marketing purposes but may share Personal Information with affiliates in order to offer services to clients that Caprock itself does not provide or to facilitate the provision of services by Caprock to its clients.
Caprock has never sold Personal Information regarding any client, employee or prospective employee to any party for any reason.
Your Privacy Rights – California
If you are a resident of California, you may have rights under the California Consumer Privacy Act of 2018 (“CCPA”), as described herein.
Your Right to Access and Request Disclosure of Information We Collect and Share About You
Caprock is committed to ensuring that you know what information we collect and share about you. You can submit a request to Caprock for the following information:
- The categories of Personal Information that Caprock has collected about you.
- The categories of sources where Caprock collected the Personal Information.
- The business or commercial purposes for why Caprock collected the Personal Information.
- The specific pieces of Personal Information we collected about you.
- The categories of third parties with whom Caprock shared your Personal Information.
- The categories of Personal Information that we’ve shared with service providers who provide services for us.
Our responses to any of these requests will cover the 12-month period preceding our receipt of the request.
Your Right to Request Deletion of Personal Information We Have Collected About You
Upon your request, we will delete the Personal Information we have collected about you, except for situations where the CCPA authorizes us to retain specific information, including when it is necessary for us to provide you with a good or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law. The law also permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us. We will act on your deletion request within the timeframes set forth below.
To exercise the right to request the disclosure or deletion of Personal Information that Caprock collects or shares about you, contact Caprock at marketing@Caprock.com or (208)368-9600. Requests are typically free of charge. If your request relates to Personal Information we may have collected from or about you when you applied for a position with us, please submit your request by contacting us at HR@caprock.com or (208)368-9600.
Our Process for Responding to Requests for Access or Deletion under the CCPA
To respond to your request, we will ask you for certain pieces of Personal Information and endeavor to match those to information we maintain about you. The nature and number of verifying data elements we may request will depend on the nature of your request and the nature of the information we maintain about you. If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. In that case, we will notify you to explain the basis of our denial.
For requests for access or deletion, we will respond to your request or your authorized agent’s request in writing as soon as practicable and in any event generally not more than within 45 days after receipt of the request. We may extend this period to 90 days and, in the event that we do extend the period, we will explain to you or your authorized agent why we did so.
If you are legally entitled to such rights, you may designate an agent to submit a request on your behalf. The agent must be a natural person or a business entity that is registered with the California Secretary of State. If you would like to designate an agent to act on your behalf, you and the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the opt-out request on your behalf. We will also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.
Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.
If you exercise any of the rights explained in this Policy, we will continue to treat you fairly. If you exercise your rights under this Policy, you will not be denied or charged different prices or rates for goods or services, or provided a different level or quality of goods or services than others.