Privacy Policy

Last Updated: November 14, 2023

Your privacy and trust are important to RollingsGroup, and so is being clear about how we collect, use, and disclose information about you. This notice is provided on behalf of RollingsGroup.

Applicability

This Privacy Policy applies to:

• RollingsGroup products and services, including Managed investing [Core, premium, and Generation] available through the RollingsGroup Website.
• RollingsGroup website, including all subpages and successor pages (collectively referred to as the “Website”).
• Any interactions with our clients, prospective clients, and prospective employees.

This Privacy Policy will continue to apply for as long as we hold your information, including after the termination of any of your products or services with us. By providing us with your personal information, you are consenting to the collection, use, and sharing of your personal information as set out in this Privacy Policy.

If we change our privacy practices, we will update this privacy policy. If any changes are significant, we will let you know.

Collection of Personal Information

Information Provided by You

• Biographical Information: May include your name, address, phone numbers, email address, birthdate, or other national or provincial identifiers provided by you when you sign up for an account.
• Financial Information: May include bank account information, transactional history, account types and balances or limits, names of financial institutions, and related financial information that we collect from you or your financial institution.
• Beneficiary Information: If you sign up for a registered retirement account, we may ask you to provide certain beneficiary information such as your spouse’s name and occupation, children’s or dependents’ names, and ages that we collect from you on your application forms.
• Photo ID: We may collect copies of government-issued identification or a picture of yourself (a “selfie”) that you provide us or one of our service providers.
• Signatures: We may collect your signature if you sign up for certain product offerings.
• Questionnaire Responses and Other Regulatory Questions: This may include asset holdings and values, and investment knowledge and objectives that you provide in risk information forms we ask you to complete.
• Referral Program Information: This may include information you provide us if you participate in our referral programs or “Invite a Friend” features. We collect contact information such as the email address of the individual who you wish to refer to RollingsGroup, and who consented to receiving the referral. We use this information to send the recipient a one-time email containing information about the referral program.
• Information Provided When Contacting Us: If you reach out to a customer service agent or advisor, you may be asked for information that identifies you (such as your name, address, or a phone number), along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may record the conversation or retain this information to assist you in the future and to improve our customer service, and product and service offerings.

Information Automatically Collected

• Service Information: We collect information that is generated through your actions when you use our app or Website, such as your transactions, interactions with our Products, your preferences, or statistics regarding your use of our services.
• Cookies and Similar Technologies: We may use cookies and similar technologies to collect log data and usage information. In general, you can visit our Website without indicating who you are or submitting any personal information. However, we collect and log the IP (Internet protocol) addresses of all visitors to the Websites and other related information such as page requests, browser type, operating system, and average time spent on the app and Website. We use this information to help us understand activity and to monitor and improve the app and Website.

Use of Personal Information

In addition to the purposes identified to you before or at the time of collection, the personal information we collect is used for the following purposes, as applicable:

• Understanding your financial needs and delivering financial products and services that help meet them.
• Helping us choose the portfolio that best fits you and your needs.
• Verifying your identity and other information you have provided to us.
• Managing your relationship among RollingsGroup Products and maintaining accurate and consistent information about you.
• Helping us manage and assess our risks and operations.
• Detecting, preventing, and suppressing errors, fraud, financial abuse, and other unauthorized or illegal activities.
• Meeting legal and regulatory requirements, including self-regulatory organizations.
• Tailoring your Website experience, including making recommendations for RollingsGroup products or services.
• De-identifying your information by removing personal identifiers such as your name and address. This information will not be used to identify individuals and may be used for analytics and reporting, developing and improving our products and services, and identifying trends and insights that may be of value to us and our clients.
• Transferring your account to or from another institution.
• As otherwise required or permitted by applicable law.

Profiling Information

We may use your data to customize your experience and generate personal information about you, such as predicting your personal preferences, economic situation, or products you may be eligible for.

Protection of Information

Safeguards

• We maintain reasonable administrative, technical, and physical safeguards in an effort to protect personal information in our custody and control against unauthorized access, use, modification, and disclosure.
• We train our employees to keep clients’ personal information strictly private and confidential. We require all of our staff to sign confidentiality agreements that oblige them to respect and protect clients’ personal information.
• We ensure that departing staff understand they remain contractually obliged to respect the privacy of clients’ personal information.

Retention and Access

• We have personal information retention processes designed to retain personal information of our clients and prospective clients for no longer than necessary for the purposes set out in this Privacy Policy or to otherwise meet legal requirements.
• We store personal information electronically on computer servers to which only authorized persons have access, and only by means of secure passwords. We authorize employees and service providers to have access to clients’ personal information only on a “need-to-know” basis in order to fulfill their job requirements.

Protection Tips for Users

To protect your user account, we encourage you to:

• Use a long and unique password for RollingsGroup. Do not use the same password across different websites or apps.
• Never share your password with anyone.
• Limit access to your computer, phone, and browser.
• Log out once you have finished using RollingsGroup on a shared device.

Rights Over Personal Information

Individuals have the right to access, update, and correct personal information in

RollingsGroup’s custody and control, subject to certain exceptions prescribed by law. You may update certain profile information you have provided to us by logging in to your account and clicking “Settings”. Otherwise, if you wish to request access, updating, and corrections of inaccuracies in personal information in our possession or control, you may send a written request to this effect to support@rollingsgroup.com. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.

Contact Information

RollingsGroup Chief Privacy Officer is responsible for ensuring that RollingsGroup adheres to its privacy policy. If you would like to make a request, a complaint, or ask a question about how we process your personal information, please contact our privacy team at support@rollingsgroup.com.