HighGround Trading Group, Inc. (“HighGround”) is dedicated to serving your financial needs. Your privacy as well as your confidence in every aspect of our relationship is important to us.
Nonpublic Personal Information Collected
We collect nonpublic personal information when you (a) open and maintain an account with us or (b) inquire as to a financial product or service offered by us. Specifically, we collect nonpublic personal information from the following sources:
- From account opening documents and any other forms delivered by you to us (such as name, address, social security number or tax identification number, assets, and income);
- From transactions made by or with us (including account balances, and cash deposits/withdrawals);
- From entities outside of HighGround (e.g., information obtained from credit rating agencies);
- From visits to the HighGround web site (cookies may be used to track your activities while on a web site, although cookies do not contain personal information about you unless you knowingly provide it); and
- From any direct inquiry regarding a HighGround product or financial service.
Sharing of Nonpublic Personal Information
We do not sell or rent customer information. We do not disclose nonpublic personal information about customers (current or former) to any nonaffiliated third parties or to affiliated entities, except as permitted by law. Such instances where information may be shared include:
- To service providers in connection with the administration and servicing of an account, which may include attorneys, accountants, auditors and other professionals;
- To affiliated companies in order to provide you with ongoing personal advice and assistance with respect to the products and services you have purchased through us and to introduce you to other products and services that may be of value to you;
- To respond to a subpoena or court order, judicial process or to regulatory authorities; and
- To protect against fraud, unauthorized transactions (such as money laundering), claims or other liabilities.
If you are a consumer and not a customer of HighGround we may share some or all of your personal information with entities not affiliated with us as permitted by law. Please be advised, however, that we only share such information with service providers that market our products or services or provide services to HighGround. Further, the information provided does not include credit information, such as credit history, net worth, or income information.
The law allows you to “opt out” of our sharing nonpublic personal information about you in certain circumstances with affiliated and nonaffiliated companies; that is, you may direct HighGround to not make such disclosures. We do not currently share information about you with any affiliate or third party that triggers this opt out right. Therefore, there is no need for you to opt out. If in the future we desire to disclose your information in a way that is inconsistent with this policy, we will notify you in advance and provide you with the opportunity to opt out of such disclosure.
We protect your account information by placing it on the secure portion of the HighGround web site, using various tools such as firewalls and data encryption, and requiring you to enter a unique username and password to access your account information online. With respect to internal security procedures, we restrict access to nonpublic personal information to those officers or employees who need to know that information to perform services to our customers. At HighGround, we value the protection of our customers’ nonpublic personal information and will continue to do our best in making sure you feel confident that our information safeguards satisfy your needs.
Updating Your Nonpublic Personal Information
We work hard to keep complete and accurate information about you and your accounts. If you ever believe that our records are incorrect or incomplete, please let us know. We will investigate and correct any inaccuracies as quickly as possible. You may also update this information by contacting us at the telephone number or e-mail address provided below. When writing, please include your name, mailing address, telephone number and, if possible, your account number.
Rosenthal Collins Group, LLC (“RCG”) recognizes that The International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (“Act”) imposes important new obligations on all financial firms for the detection, deterrence and reporting of money laundering activities. Under the Act, money laundering is defined as any financial transaction using income derived from criminal activity including, but not limited to, drug trafficking, fraud, illegal gambling and terrorism. RCG has established the following policies to ensure thorough compliance with all laws and regulations regarding money laundering.
Prior to the opening of any new account, RCG shall document the identity, nature of business, income, source of assets, and investment objectives of each prospective customer. Accounts for persons or entities from countries that do not cooperate with the Financial Action Task Force (FATF) guidelines on money laundering shall be subject to a heightened level of scrutiny. Accounts in the name of, or related to, any person or entity on the Office of Foreign Asset Control (OFAC) Specially Designated Nationals and Blocked Person list shall not permitted.
On an ongoing basis, RCG shall review account activity for evidence of suspicious transactions that may be indicative of money laundering activities. This review may include surveillance of: 1) money flows into and out of accounts, 2) the origin and destination of wire transfers, 3) non-economic transactions, and 4) other activity outside the normal course of business.
Every officer, employee and associated person (“AP”) of RCG shall be responsible for assisting in the firm’s efforts to uncover and report any activity that might constitute, indicate or raise suspicions of money laundering. To this end, RCG shall provide continuing education and training of all such persons.
Should any officer, employee or AP of RCG have any knowledge, suspicions or information regarding potential money laundering activities, that individual shall immediately notify RCG’s Compliance Department. RCG’s Compliance Officer shall document the reported activity, investigate fully, and, if warranted, report such activity to the senior management of RCG.
RCG shall comply with all trade and economic sanctions imposed by OFAC against targeted foreign countries and shall cooperate fully with government agencies, self-regulatory organizations and law enforcement officials. As provided by the Act, RCG may supply information about former, current or prospective customers to such bodies.
Any officer, employee or AP who fails to comply with RCG’s policies and procedures on money laundering may be subject to disciplinary action, including termination of employment. In addition, such failure may expose the individual to civil and criminal penalties under the Act.