Privacy Notice
Rockbridge Capital Management, LLC collects, uses, and safeguards Nonpublic Personal Information (NPI) about its investors as necessary to conduct business and provide investment services. This is in accordance with applicable laws and regulations, most specifically Regulation S-P and those issued by the U.S. Securities and Exchange Commission (SEC). NPI refers to personally identifiable information that is not publicly available, including but not limited to an individual’s name, address, Social Security number or tax identification number, bank account details, and investment-related information. This information is obtained through means such as subscription documents, investor questionnaires, and in-person meetings. Rockbridge Capital Management, LLC’s Privacy Policy applies to both current and former clients.
Commitment to Privacy
Rockbridge Capital Management, LLC is sensitive to the privacy concerns of prospective, former and current clients. The Firm is committed to protecting the confidentiality and security of information it collects. Rockbridge Capital Management, LLC is providing this notice to help our clients better understand why and how the Firm collects certain personal information, the care with which it treats that information and how it uses that information. Rockbridge Capital Management, LLC complies with SEC regulations to maintain the privacy of its clients’ and its prospective clients’ NPI. Any violation of the procedures and policies set forth in this Privacy Policy may result in termination of employment or contract with Rockbridge Capital Management LLC. The Chief Compliance Officer will confirm the delivery of a copy of the Firm’s Privacy Notice to all prospective clients and employees. For vendors, the Privacy Notice is available upon request.
Disclosure of Nonpublic Personal Information
Rockbridge Capital Management, LLC may disclose NPI only as necessary to provide services and conduct business operations. Disclosures may also be made to comply with legal or regulatory obligations, respond to regulatory authorities, protect against fraud, or with the client’s consent.
Network Storage with Cloud Service Providers
Rockbridge Capital Management, LLC engages cloud-based service providers for the storage of Client NPI. In coordination with its IT service provider, the Firm and Vendor comply with SEC regulations regarding the cloud-based storage of NPI.
Disclosure of Information
Rockbridge Capital Management, LLC does not knowingly disclose NPI to any other person or entity except its employees, third party professional vendors who are provided with access to such information to carry out operations, or as otherwise required by law or regulation. These sharing practices are consistent with federal privacy and related laws.
Further Information
Rockbridge Capital Management, LLC reserves the right to change its Privacy Policies and this Privacy Notice at any time. Clients will be provided with any material updates of changes to this Privacy Policy. The examples contained within this notice are illustrations only and are not intended to be exclusive. This notice is intended to comply with the privacy provisions of applicable U.S. federal law. There may be additional rights under other foreign or domestic laws that apply to you. If you have any questions concerning this Privacy Notice, please contact Rockbridge Capital Management LLC’s Chief Compliance Officer.