Privacy Notice

Last Updated: September 30, 2024

Controller Details

Rodman & Renshaw LLC
600 Lexington Avenue, 32nd Floor
New York, NY

Contact: privacy@rodm.com

This Privacy Notice of Rodman & Renshaw LLC (“Company,” “us,” “we,” and “our”) describes the information we collect about you when you access our website at https://www.rodm.com (the “Site”), enter into agreements with us, use our services and purchase products, send us communications, or otherwise engage with us, and what we do with such information. Any references to the Company in this Privacy Notice also refer to its wholly owned subsidiaries. This Privacy Notice covers all of our services and products and all methods by which you may access our Site.

Scope of This Notice

This Privacy Notice applies to all Personal Information collected by our Site (“Personal Information”). For the purposes of this Privacy Notice, Personal information means a natural person’s first name or first initial and last name in combination with any one or more of the following data elements when the name and data elements are not encrypted: social security number, driver’s license number, driver authorization card number, or identification card number; account number, credit card number, or debit card number, in combination with any required security code, access code, or password that would permit access to the person’s financial account; a medical identification number or a health insurance identification number; a username, unique identifier, or electronic mail address in combination with a password, access code, or security question and answer that would permit access to an online account.

Topics Covered in Our Privacy Notice

Summary of Privacy Notice

1) WHAT DOES RODMAN & RENSHAW LLC DO WITH YOUR PERSONAL INFORMATION

2) HOW DO WE USE AND SHARE YOUR PERSONAL INFORMATION

3) WHO WE ARE

4) WHAT WE DO

5) KEY DEFINITIONS

Privacy Notice

1) HOW WE COLLECT, USE AND SHARE YOUR INFORMATION

2) RETAINING AND DESTROYING YOUR PERSONAL INFORMATION

3) UPDATING YOUR PERSONAL INFORMATION

4) REVOKING YOUR CONSENT FOR USING YOUR PERSONAL INFORMATION

5) DO NOT TRACK SETTINGS

6) LINKS TO OTHER WEBSITES

7) PROTECTING CHILDREN’S PRIVACY

8) OUR EMAIL POLICY

9) OUR SECURITY POLICY

10) OUR COOKIE POLICY

11) PAYMENTS

12) ADDENDUM FOR CALIFORNIA RESIDENTS

13) GENERAL DATA PROTECTION REGULATION (“GDPR”)

14) CHANGES TO OUR PRIVACY NOTICE

HOW WE COLLECT, USE AND SHARE YOUR INFORMATION

Personal Information We Collect ¹

We may collect, store, use, and transfer the following types of Personal Information:

Identity Data such as name, mailing address, email address, telephone and mobile number.

Transaction Data such as credit card or other payment information.

Purposes and Legal Basis of Collection and Processing of Personal Information

How We Collect Information

Direct Interactions. You provide Personal Information when you use our services and products, open an account with us, request marketing information, engage with our social channels and/or contact us with questions or requests.

Technological Interactions. When you use our services and products, use our applications, or visit our Site, we may collect device data and online data through cookies and other similar technologies (see Cookies and Automatically Collected Data).

How We Use Your Personal Information

We use information that we collect about you or that you provide to us, including any Personal Information:

• To present our Site, and its contents to you.
• To provide you with the information that you request from us.
• To fulfill any other purpose for which you provide it.
• To notify you about changes to our Site.
• To allow you to participate in interactive features on our Site.
• In any other way, we may describe when you provide the information.
• For any other purpose with your consent.
• Research and development purposes. We may use Personal Information for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us to make our services more convenient and easier-to-use, enhance the safety and security of our services, and develop new services and features.
• Marketing. We may use Personal Information to market our services to our users. This includes sending users communications about our services, features, promotions, studies, surveys, news, updates, and events. We may do so through various methods, including email, text messages, push notifications, in-app communications and ads, and ads on thirdparty platforms.
• Legal proceedings and requirements. We may use Personal Information to investigate or address claims or disputes relating to the use of our services, to satisfy requirements under applicable laws, regulations, or operating licenses or agreements, or pursuant to legal process or governmental request, including from law enforcement.
• Non-marketing communications. We may use Personal Information to inform you of changes to our terms, services, or policies; or send other communications that aren’t for the purpose of marketing the services or products of the Company or its partners.

We will not use your Personal Information for purposes other than those purposes we have disclosed to you without your permission. If we need to use your Personal Information for an unrelated, new, or additional purpose, we will notify you and obtain your consent to use it for such unrelated, new, or additional purpose

Sharing Your Personal Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may share your Personal Information with our business partners. The business partners also include general business partners, affiliates, and joint venture partners. We share this information with them so that they can send you information about our products and services as well as their products and services. When you choose to take part in our services and/or offerings, you are authorizing us to provide your email address and other Personal Information to our business partners. Please understand that when we share your Personal Information with our business partners, your Personal Information becomes subject to our business partners as well as our Privacy Notice.

We may disclose Personal Information that we collect, or you provide as described in this Privacy Notice:

• To our subsidiaries and affiliates
• To contractors and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by the Company about our users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• When you share personal information or otherwise interact in the public areas of the Site with other users, such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through, e.g., a Third-Party Social Media Service, your contacts on the Third-Party Social Media Service may see your name, profile, pictures and description of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you and view your profile. We may use third-party products and/or services to provide us with sponsored conferences or events virtual or otherwise, and key opinion leader (“KOL”) calls. We may share your personal information with third parties to provide you with access to such Events. Thirdparty services that we have used or may use include Wall Street Transcript Corporation, a.k.a., MeetMax (“MeetMax”) and Guidepoint Global, LLC. For more information about these services and their privacy policies, please visit their websites. (https://www.meetmax.com/), (https://guidepoint.com/).
• With your consent.

We may also disclose your Personal Information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

To enforce or apply our Terms of Use3 and other agreements, including for billing and collection purposes.

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

Sale of Your Personal Information

We do not sell your Personal Information.

UPDATING YOUR PERSONAL INFORMATION

You can update your Personal Information using services found on our Site. If no such services exist, you can contact us using the contact information found at the top of this Privacy Notice and we will help you. However, we may keep your Personal Information as needed to enforce our agreements and to comply with any legal obligations.

REVOKING YOUR CONSENT FOR USING YOUR PERSONAL INFORMATION

You have the right to revoke your consent granted for us to use your Personal Information at any time. Such opt-out will not affect disclosures otherwise permitted by law including but not limited to: (i) disclosures to affiliates and business partners, (ii) disclosures to third-party service providers that provide certain services for our business, such as payment processors, web analytics companies, advertising networks, call centers, data management services, help desk providers, accountants, law firms, auditors, shopping cart and email service providers, and shipping companies, (iii) disclosures to third parties as necessary to fulfill your requests, (iv) disclosures to governmental agencies or law enforcement departments, or as otherwise required to be made under applicable law, (v) previously completed disclosures to third parties, or (vi) disclosures to third parties in connection with subsequent contests or promotions you may choose to enter, or thirdparty offers you may choose to accept. If you want to revoke your consent for us to use your Personal Information, please contact us through the contact information at the top of this Privacy Notice.

DO NOT TRACK SETTINGS

Some web browsers have settings that enable you to request that we do not track your movement within our Site. Our Site does not obey such settings when transmitted to and detected by our Site. You can turn off tracking features and other security settings in your browser by referring to your browser’s user manual.

LINKS TO OTHER WEBSITES

Our Site may contain links to other websites. These websites are not under our control and are not subject to our Privacy Notice. These websites will likely have their own Privacy Policies. We have no responsibility for these websites, and we provide links to these websites solely for your convenience. You acknowledge that your use of and access to these websites are solely at your risk. It is your responsibility to check the Privacy Notices of these websites to see how they treat your Personal Information.

PROTECTING CHILDREN’S PRIVACY

Even though our Site is not designed for use by anyone under the age of 16, we realize that a child under the age of 16 may attempt to access our Site. We do not knowingly collect Personal Information from children under the age of 16. If you are a parent or guardian and believe that your child is using our Site, please contact us. Before we remove any information we may ask for proof of identification to prevent malicious removal of account information. If we discover that a child is accessing our Site, we will delete their information within a reasonable period of time. You acknowledge that we do not verify the age of our users nor have any liability to do so.

OUR EMAIL POLICY

We may use third-party email marketing service providers to manage and send emails to you. We may use your personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us. Third-party services that we used or may use in the future include Twilio, Inc. and Constant Contact, Inc. For more information about these services and their privacy policies, please visit their websites. (https://www.twilio.com/), (https://www.constantcontact.com/).

OUR SECURITY POLICY

We have built our Site using industry-standard security measures and authentication tools to protect the security of your Personal Information. We and the third parties who provide services to us also maintain technical and physical safeguards to protect your Personal Information. Unfortunately, we cannot guarantee prevention of loss or misuse of your Personal Information or secure data transmission over the Internet because of its nature. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your Personal Information transmitted to our Site.

OUR COOKIE POLICY

To ensure that our Site functions properly, we sometimes place small data files called cookies on the user's device. We use cookies to analyze the online behavior of the user. The purpose is to use the information to improve the structure of the web content and usability.

What are Cookies?

Cookies are small text files sent from a site to a user’s device to store bits of information related to that user or device. First-party cookies are put on your device directly by our Site, which allows us to collect analytical data and provide other useful functions that create a good user experience. Third-party cookies are placed on your device by a third party (e.g.: an advertiser or analytic system). The third parties who serve cookies on our site may link your Personal Information to other information they collect.

Certain features of our Site may use locally stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies.

Pages of our Site and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

“Clickstream” data (e.g., information regarding which of our Site pages you access, the frequency of such access, and your product and service preferences) may be collected by us, or by our service providers, using cookies, web beacons, page tags, or similar tools that are set when you visit the Site or when you view an advertisement we may have placed on another website. Clickstream data and similar information may be shared internally within the Company and used for administrative purposes to assess the usage, value and performance of our online products and services; to improve your experience with the Site; and as otherwise permitted by applicable law or regulation. This information may be processed by us for the purposes described above, or on our behalf by other entities, solely in accordance with our instructions.

We use functional cookies only. Functional Cookies allow us to provide enhanced functionality. For example, we use these cookies to notify you of account updates, notifications, and reminders. You may refuse to accept these cookies; however, this may affect access to certain parts of our website. Additionally, you may not be able to take advantage of personalized features

PAYMENTS

We may provide paid products and/or services within our Site. In that case, we may use third-party ervices for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your Personal Information is governed by their Privacy Notice, we have no control over them. We use commercially reasonable efforts to ensure that your credit card number is kept strictly confidential by using only third-party payment services that use industry-standard encryption technology to protect your credit card number from unauthorized use. Third-party services that we used or may use include Fattmerchant Inc. and Paya, Inc. For more information about these services and their privacy policies, please visit their websites. (https://fattmerchant.com/), (https://paya.com/).

ADDENDUM FOR CALIFORNIA RESIDENTS

If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data and not to sell (share) it. To exercise your data protection rights, you can make certain requests and ask us:

What Personal Information Do We have about You. If you make this request, we will return to you:

• The categories of Personal Information we have collected about you.
• The categories of sources from which we collect your Personal Information.
• The business or commercial purpose for collecting or selling your Personal Information.
• The categories of third parties with whom we share Personal Information.
• The specific pieces of Personal Information we have collected about you.
• A list of categories of Personal Information that we have sold, along with the category of any other company we sold it to. If we have not sold your Personal Information, we will inform you of that fact.
• A list of categories of Personal Information that we have disclosed for a business purpose, along with the category of any other company we shared it with.

Please note, you are entitled to ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to the Personal Information we collected about you in the previous 12 months.

To Delete Your Personal Information

If you make this request, we will delete the Personal Information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your Personal Information, you may not be able to use certain functions that require your Personal Information to operate.

To Stop Selling Your Personal Information

If you submit a request to stop selling your Personal Information, we will stop selling it. If you are a California resident, to opt-out of the sale of your Personal Information, click “Do Not Sell My Personal Information” at the bottom of our home page to submit your request.

Please note, if you ask us to delete or stop selling your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services that require the usage of your Personal Information to function. But in no circumstances, we will discriminate against you for exercising your rights.

To exercise your California data protection rights described above, please send your request(s) by one of the following means:

By email: privacy@rodm.com

Your data protection rights, described above, are covered by the CCPA, short for the California Consumer Privacy Act. To find out more, visit the official California Legislative Information website. The CCPA took effect on 01/01/2020.

Mobile devices

Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests: "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices "Limit Ad Tracking" on iOS devices You can also stop the collection of location information from Your mobile device by changing the preferences on your mobile device.

GENERAL DATA PROTECTION REGULATION (“GDPR”)

If you want to exercise any of your rights included in this Privacy Notice, contact us at privacy@rodm.com.

In connection with the accessing, browsing of the Site and using the services, you shall be entitled to exercise certain rights laid down by the GDPR, CPRA, similar privacy laws and the policies outlined herein, however, exercise of some of those rights may not be possible in relation to the Site and services taking account of the services’ nature, manner, form and other applicable circumstances. In some cases, we may ask you to provide us with additional evidence and information confirming your identity.

• Right to Be Informed: you have the right to be informed about the Personal Information that we collect from you and how we process them.
• Right to Rectification: if your Personal Information is inaccurate, you have the right to have the data rectified without undue delay.
• Right to Access: you may request access to all Personal Information being processed about you.
• Right to Erasure (Right to Be Forgotten): the right to request the removal or deletion of your Personal Information if there is no compelling reason for us to continue processing them.
• Right to Restrict Processing: you have the right to ‘block’ or restrict the processing of your Personal Information. When your Personal Information is restricted, we are permitted to store your data, but not to process them further.
• Right to Data Portability: you have the right to request your Personal Information that you provided to us and use them for your own purposes. We will provide your data to you within 30 days of your request. Contact us using the information at the top of this Privacy Notice to request your Personal Information.
• Right to Object: you have the right to object to us processing your Personal Information for the following reasons:
  • Processing was based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling).
  • Direct marketing (including profiling).
  • Processing for purposes of scientific/historical research and statistics.
  • Rights in relation to automated decision-making and profiling.
• Automated Individual Decision-Making and Profiling: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects regarding you or similarly significantly affects you.
• Filing a Complaint with Authorities: you have the right to file a complaint with supervisory authorities if your information has not been processed in compliance with the applicable law. If the supervisory authorities fail to address your complaint properly, you may have the right to a judicial remedy.

International Data Transfer

We may transfer information collected about you, including Personal Information, to affiliated entities, or to other third-party service providers across borders and from your country or jurisdiction to other countries or jurisdictions around the world (all solely for legitimate business purposes). Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information. Such jurisdictions are the US and the EU/EEA

Personal Information that we collect from you may be stored, processed, and transferred among any countries in which we operate. The European Union has not found the United States and some other countries to have an adequate level of protection of Personal Information under Article 45 of the GDPR. Our company relies on derogations for specific situations as defined in Article 49 of the GDPR. If you are a European Union customer or user, with your consent your Personal Information may be transferred to the United States or other countries outside the European Union when you request information from us. When you buy goods or services from us, we will use your Personal Information for the performance of a contract or to take steps to enter into a contract. Wherever we transfer, process, or store your Personal Information, we will take reasonable steps to protect it. We will use the information we collect from you in accordance with our Privacy Notice. By using our Site, services, or products you agree to the transfers of your Personal Information described within this section.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to change this Privacy Notice at any time. If our company decides to change this Privacy Notice, we will post those changes on our Site so that our users and customers are always aware of what information we collect, use, and disclose. If at any time we decide to disclose or use your Personal Information in a method different from that specified at the time it was collected, we will provide advance notice by email sent to the email address on file in your account. Otherwise we will use and disclose our users’ and customers’ Personal Information in agreement with the Privacy Notice in effect when the information was collected. In all cases your continued use of our Site, services, and products after any change to this Privacy Notice will constitute your acceptance of such change. If you have questions about our Privacy Notice, please contact us through the information at the top of this Privacy Notice.