Date Last Updated: March 28, 2022

ROECNY GROUP LLC (“ROECNY”) operates the platform as known www.roecny.com(Roecny Digital Banking Platform). It is ROECNY’s policy to maintain the confidentiality, integrity, and security of any personal information about its users. This Privacy & Security Policy (“Policy”) explains how ROECNY (“We”, “Us”, or “Our”) collects, uses, shares, and keeps secure your information (“You”, “you”, “Your”, or “User”), including your nonpublic personal information, when You use ROECNY’s website www.roecny.com and www.roecnybank.com (the “Website”), mobile application (the “App”), and any related products and services (collectively referred to as the “Services”). By using Our Services, you are agreeing to this Policy. If you do not agree to these terms, you may not enroll in or use the Services. Pursuant to this Policy, You direct Our partner financial institution(s) to share your transactional data with ROECNY, and you direct ROECNY to share your data with its users, vendors, partners, and affiliates at its discretion, in a way that would otherwise be contrary to this Policy.

1. Website Visitors
Like most website operators, ROECNY collects non-personally-identifying information that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. ROECNY’s purpose in collecting non-personally identifying information is to better understand how ROECNY’s visitors use its website. From time to time, ROECNY may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its website. ROECNY also collects potentially personally-identifying information like Internet Protocol (IP) addresses for logged in Users and for Users leaving comments on blogs. ROECNY only discloses logged in User and commenter IP addresses under the same circumstances that it uses and discloses personally-identifying information as described below, except that blog commenter IP addresses and email addresses are visible and disclosed to the administrators of the blog where the comment was left. ROECNY collects such information only insofar as is necessary or appropriate to fulfill the purpose of the visitor’s interaction with ROECNY. ROECNY does not disclose personally-identifying information. And visitors can always refuse to supply personally-identifying information, with the caveat that it may prevent them from engaging in certain Services.

2. Customers of ROECNY
GATHERING OF PERSONALLY-IDENTIFYING INFORMATION The amount and type of information that ROECNY gathers depend on the nature of the interaction. Certain visitors to ROECNY’s websites choose to interact with ROECNY in ways that require ROECNY to gather personally-identifying information, most notably when becoming a “Customer” (which means that you have registered with ROECNY to use its App or related products or services). Registration involves the provision of an email address, a password, and a PIN (collectively the “Registration Information”). In order to benefit from the full functionality of the Services, you also must provide your third-party account credentials (“Account Credentials”) to allow ROECNY and our partners to access your account data at those other financial institutions (“Account Information”) for your use. To help the government fight the funding of terrorism and money laundering activities, the USA PATRIOT Act, a Federal law, requires financial institutions to obtain, verify, and record information that identifies each business that opens an account and the personal information of its owners or representatives. Therefore, when applying to become a Customer, ROECNY, on behalf of its partner financial institution, We will collect personally-identifying information about You personally and about Your business to establish and maintain Your account. Personal information may include, but is not limited to, your name, personal address (residential address required, no PO box address allowed), date of birth, social security number (SSN), and other similar information. Business information may include, but is not limited to, your business name, tax identification number, business address, business telephone number, business bank account information, business-related documentation, telephone number, and email address. Additional information will be requested at account opening and may be requested throughout the life of the account relationship to meet regulatory and legal requirements. If you choose to provide us with personal information, business information, financial information, and financial data, you consent to the transfer and storage of that information on our servers located within the United States.

USE OF PERSONALLY-IDENTIFYING INFORMATION
ROECNY and its affiliated companies use and disclose User’s personal information to provide the Services, including for the purposes of: Analyzing site usage and improving the Service; Delivering to You any administrative notices, alerts, and communications relevant to your use of the Service; Marketing Our products and services and those of our business partners that We believe may be of interest to You; Fulfilling Your requests for certain products and services; Market research, project planning, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity; Third-party contractors providing services to ROECNY which are bound by these same privacy restrictions; Enforcing Our Terms of Use; and As otherwise set forth in this Privacy and Security Policy (including disclosures to protect our rights, if required by law, or relating to a transfer of control or sale of assets).

3. Third Parties
The Services may present you information relating to third party products or services (ROECNY Offers), as well as provide you general tips, recommendations and educational material. When using our Services, You may have the option to provide Us with information from third parties, such as Facebook, Twitter, Google, and LinkedIn. We may also acquire information about You from third parties in order to verify your identity, process Your transactions, detect and prevent fraud, or other similar purposes. We are not responsible for the privacy practices of any third parties or the content of sites that are linked from our Services. We strongly encourage you to read the applicable privacy policies and terms and conditions of such parties or websites.

4. Protection of Certain Personally-Identifying Information
ROECNY discloses potentially personally-identifying and personally-identifying information only to those of its employees, contractors and affiliated organizations that (i) need to know that information in order to process it on ROECNY’s behalf or to provide services available at ROECNY’s websites, and (ii) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using ROECNY’s Services, you consent to the transfer of such information to them. ROECNY will not rent or sell potentially personally-identifying and personally-identifying information to anyone. Other than to its employees, contractors and affiliated organizations, as described above, ROECNY discloses potentially personally-identifying and personally-identifying information only in response to a subpoena, court order or other governmental requests, or when ROECNY believes in good faith that disclosure is reasonably necessary to protect the property or rights of ROECNY, third parties or the public at large. If you are a registered user of ROECNY Services (i.e. Customer) and have supplied your email address, ROECNY may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with ROECNY and our products. We primarily use our various product blogs to communicate this type of information, so we expect to keep this type of email to a minimum. If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users. ROECNY takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information. The security of your personal information is important to us. We utilize physical, electronic and procedural security measures to protect against loss, misuse, and alteration of information under our control. We offer industry-standard practices and security measures to safeguard and secure the personal information we collect. However, some of the applications or networks that you use may not be completely secure, thus we cannot guarantee absolute security.

If you are a registered user of ROECNY Services (i.e. Customer) and have supplied your email address, ROECNY may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with ROECNY and our products. We primarily use our various product blogs to communicate this type of information, so we expect to keep this type of email to a minimum. If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users. ROECNY takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information. The security of your personal information is important to us. We utilize physical, electronic and procedural security measures to protect against loss, misuse, and alteration of information under our control. We offer industry-standard practices and security measures to safeguard and secure the personal information we collect. However, some of the applications or networks that you use may not be completely secure, thus we cannot guarantee absolute security.

5. Cookies & Other Technologies
We may also use various technologies to collect and store information related to Your use of our Services. We may collect and store information locally on your device using mechanisms such as browser web storage and application data caches. A cookie is a string of information that a website stores on a visitor’s computer and that the visitor’s browser provides to the website each time the visitor returns. ROECNY uses cookies to help ROECNY identify and track visitors, their usage of any ROECNY websites, and their website access preferences. ROECNY visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using ROECNY’s websites, with the drawback that certain features of ROECNY’s Services may not function properly without the aid of cookies.

6. Business Transfers
If ROECNY, or substantially all of its assets, are acquired, or in the event that ROECNY goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of ROECNY may continue to use Your personal information as set forth in this Policy.

7. Ads
Ads appearing on any of our websites may be delivered to users by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This Policy covers the use of cookies by ROECNY and does not cover the use of cookies by any advertisers.

8. Privacy Policy Changes
ROECNY, in its sole discretion may change its Privacy & Security Policy from time to time. If we make changes, we will notify you by posting the updated Policy and revising the “Date Last Updated” above. ROECNY encourages You to frequently check this page for any changes to this Policy. Changes take effect immediately upon posting. In some cases, we may provide You with additional notice (such as by adding a statement to the homepages of our website or mobile application or by sending you an email notification). We encourage you to review the Privacy Policy whenever you interact with Us to stay informed about our information practices and the ways you can help protect your privacy. Your continued use of the Services after any change in this Policy will constitute your acceptance of such changes.

9. Opting Out of This Policy
If you no longer wish to use our Services and would like to delete or deactivate your account, please contact us at cs@roecny.com We are required by law to retain your information, and may also do so for legitimate business purposes, including internal analytics. However, we will not share or use your information for promotional and marketing purposes (except in an anonymized or de-identified form) after you have deleted or deactivated your account. As previously noted, your usage of our Services is contingent on your expressly opting in to this Policy.

10. Social Media
Regarding your creating an account or logging into the Website or App through a social media service or similar tool, such as Log in with Facebook or Sign in with Twitter (whether the use of such tools to sign in is optional or mandatory), any information that these third party social media sites collect as a function of your using those sign-in tools is subject to those respective entities’ own privacy policies. If you sign-in to the Website or App using such third party sign-in tools, certain personally identifiable information from those third party websites or services may be shared with ROECNY. We will treat this information shared with us in accordance with this Policy.

11. Indemnification
You are entirely responsible for maintaining the confidentiality of your username(s), password(s), and your account(s), as well as all activities that occur under your account(s). You hereby agree to indemnify, defend, and hold us, our agents, representatives and other authorized users, and each of the foregoing entities’ respective officers, directors, owners, employees, agents, representatives and assigns (collectively the “Indemnified Parties”) harmless from and against any and all losses, damages, liabilities and costs incurred by the Indemnified Parties in connection with any claim arising out of any breach by you of this Policy or claims arising from Our Services. You agree to use your best efforts to cooperate with us in the defense of any claim. We reserve the right, at our own expense, to employ separate counsel and assume the exclusive defense and control of any matter otherwise subject to indemnification by you.

12. Contact Us
Please contact ROECNY with any questions or concerns regarding our policy.

ROECNY GROUP LLC.

99 Wall Street #2099, New York NY 10005

Or by e-mail at: cs@roecny.com