Privacy Statement / Customer Privacy Notice / Use of Information / CPRA Job Applicant Privacy Notice

Protecting your privacy is important to CastleOak Securities, LP and our employees. We believe the confidentiality and protection of customer information is one of our most fundamental responsibilities. Whether you are an existing customer or are considering a relationship with us, you have an interest in how we collect, use, retain and secure nonpublic personal information. And while information is critical to providing quality services, we recognize that one of our most important assets is our customers’ trust.

If we change our privacy policies, a revised customer privacy notice will promptly be posted to our web site (www.castleoaklp.com). You agree to accept posting of a revised customer privacy notice electronically on the web site as actual notice to you. You should review the customer privacy notice periodically to remain informed of any changes. Any dispute between you and CastleOak Securities, LP is subject to our customer agreement/terms and conditions and our general policies, terms, and procedures governing CastleOak customer and other accounts, including where applicable, arbitration of disputes and limitation of damages.

If you have any questions that this customer privacy notice does not address or if you wish to discuss CastleOak’s privacy policies in greater detail, please contact our Compliance Department at 212 829-4776 or write us at CastleOak Securities, LP, Attn: Compliance Department, 200 Vesey Street, 4th Floor New York, NY 10281.

The Information We Collect
CastleOak may collect non-public personal information about you from the following sources: 1. Information you provide to us on account opening documentation, applications, subscriptions or other forms; 2. Transactions with us, our affiliates, or others; 3. From non-affiliated third parties (e.g., credit reporting agencies and others).

Categories of Information that We May Disclose
We may disclose the following kinds of non-public personal information about you: 1. Information we receive on applications or other forms, such as name, address, social security number and e-mail address; 2. Information about your transactions with us, our affiliates, or other; 3. Information we receive from a consumer reporting agency, such as creditworthiness and credit history.

Parties to Whom We May Disclose Information
We do not disclose non-public personal information to any non-affiliated third party, except to non affiliated third parties that may assist us in servicing your account, to financial service institutions with whom we have joint marketing agreements, to securities and banking regulators upon requests, to others pursuant to subpoena and otherwise as permitted by law. We may from time to time disclose your non-public personal information to our affiliates, including but not limited to affiliated broker-dealers.

If you decide to close your account (s) or become an inactive customer, we will continue to adhere to the privacy and practices described in this notice, or subsequent notices, which may amend the policy stated herein.

Nothing in this customer privacy notice is intended to interfere with our ability to transfer all or part of our business and/or assets to an affiliate or non-affiliated third party at any time, for any purpose, without any limitation whatsoever.

Confidentiality and Security Procedures
CastleOak Securities, L.P. takes steps to safeguard customer intimation and restrict access to your personal and account information to those employees who need to know that information in order for us to provide products or services to you. We emphasize the importance of confidentiality through employee training, operating procedures, written policies and this privacy policy. We maintain physical, electronic, and procedural safeguards to guard your non-public personal information.

Key Terms to Privacy
“Nonpublic Personal Information” – Personally identifiable financial information that is provided by a customer or potential customer to a financial institution, that results from a transaction with the customer or that is otherwise obtained by the financial institution in connection with providing a financial product or service.

“Affiliate”- Any entity that is part of CastleOak’s family by virtue of common ownership or control.

“Non-Affiliated Third Party” – Any entity that is not part of CastleOak’s family of companies.

Our Use of Cookies and Your Options

By using CastleOak’s Web site with your browser settings adjusted to accept cookies you consent to our use of cookies and other tools to provide the products and services available on  website. If you would like to modify your browser to notify you when you receive a new cookie or to disable cookies altogether, please refer to Managing Cookies below.

Cookies and How We Use Them
Cookies are small text files that may be placed on your Web browser when you visit our Web Site or when you view advertisements we have placed on other Web Site. Cookies allow your browser to remember some specific information which the Web server can later retrieve and use.  When you quit your browser, some cookies are stored in your computer’s memory, while some expire or disappear.

Cookies are used primarily for administrative purposes, to improve your experience with our Web Site. Examples of this would include the use of cookies:

In addition to administrative uses, we may also use cookies in one or more of the following ways:

This paragraph applies only to the www.castleoaklp.com web site. The site may use third parties to serve advertisements as described immediately above. To do so, these parties may place or recognize a unique cookie on your browser (including through the use of pixel tags) to gather information concerning your use of our that site and other Web Site and, based on that information, serve advertisements that may be of interest to you. If you would like more information about this practice, and to learn how to opt out of it on the particular device on which you are accessing this Privacy and Cookies Policy, please visit http://optout.aboutads.info/#/. The CastleOak Web Site adheres to the interest-based advertising principles of the Digital Advertising Alliance, available at http://www.aboutads.info/principles.

For more information on how we collect and use information that is identifiable to you, please refer to our Privacy Policy.

Managing Cookies
The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on’s settings or visiting the Web site of its manufacturer. Some of our sites employ “functionality cookies” that help the site remember your settings and preferences for use when you visit the site in the future. This provides a more tailored and pleasant user experience. These cookies store information in multiple places. On those site using functionality cookies, you will find a “Delete Cookies” feature on every page that will allow you to delete these cookies completely from your device. Please note that, if you decline to use cookies, you may experience reduced functionality and, for sites using authentication-related cookies, declining cookies will prevent you from using the Web site altogether. To learn more about what cookies are set on your computer as you browse the Web and how to manage or delete them, visit www.allaboutcookies.org.

CPRA Job Applicant Privacy Notice  
For applicants residing in California
Last updated: December 15, 2022. In connection with your job application and potential employment with CastleOak Securities, L.P. (“CastleOak,” “we,” “us,” or “our”), CastleOak will collect and use personal information for human resources, employment, benefits administration, health and safety, and other business-related purposes, as well as in order to comply with applicable laws and regulations.  We will not sell the personal information we collect in connection with your job application, nor will we share it with third parties for cross-context behavioral advertising. To view our full website privacy policy, please visit https://www.castleoaklp.com/privacy-policy. We may collect the personal information and sensitive personal information categories listed in the tables below. The tables also list, for each category, our expected retention period.  

Personal Information Category
Identifiers
, such as your full name,  gender, date of birth, signature, home address, telephone numbers, email  addresses, and emergency contact information: 1 year after the position is filled
Professional or employment-related information, such  as your job title, position, hire dates, work history, compensation,  performance and disciplinary records, and vacation and sick leave records: 1 year after the position is filled
Non-public educational information, such  as academic and professional qualifications, educational records, and  references: 1 year after the position is filled Information related to immigration status, such  as visa information, immigration status, and related documentation1 year after the position is filled
Inferences drawn from the above information, such  as assessments and summaries about your qualifications, preferences,  characteristics, attitudes, intelligence, abilities, and aptitudes1 year after the position is filled   

Sensitive Personal Information Category
Racial or ethnic origin:
 1 year after the position is filled
Personal information collected and analyzed  concerning your health, including health conditions (if  relevant to your employment), job restrictions, workplace illness and injury  information, and health insurance policy information: 1 year after the position is filled

‍CastleOak collects, uses and discloses the categories of personal informationlisted above in order to recruit and evaluate job applicants for employment, conductbackground checks, and comply with applicable laws and regulations. 

If we hire you, we may keep, use and disclose the categories of personal information listed above for the following business purposes in connection with your employment: Manage your employment relationship with us, including for: Onboarding processes;  Timekeeping, payroll, and expense report administration;  Employee benefits administration;  Employee training and development requirements;  The creation, maintenance, and security of your online employee accounts;  Workers’ compensation claims management;  Employee job performance, including goals and performance reviews, promotions, discipline, and termination; and Manage and monitor employee access to company facilities, equipment, and systems; Conduct internal audits and workplace investigations; Investigate and enforce compliance with and potential breaches of CastleOak policies and procedures; Engage in corporate transactions requiring review of employee records, such as for evaluating potential mergers and acquisitions of CastleOak; Maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance; Perform workforce analytics, data analytics, and benchmarking; Administer and maintain CastleOak operations, including for safety purposes; Client marketing purposes; Exercise or defend the legal rights of CastleOak and its employees, affiliates, customers, contractors, and agents; and Comply with applicable laws and regulations.  

You have the following rights regarding your personal information: 
Right to Know: You have the right to know: The categories of specific personal information we collect, use, disclose, sell, and/or share; and The specific pieces of personal information we have collected from or about you.
Right to Delete: You have the right to request deletion of your personal information. We will honor such request, but might not be able to fulfill your request if we (or our service providers) are legally required to retain your personal information.
Right to Correct: You have the right to request that we correct inaccurate personal information about you. We will honor such request, but might not be able to fulfill your request if it is impossible to do so or would involve disproportionate effort, or if we have a good-faith, reasonable, and documented belief that a request to correct is fraudulent or abusive. 
Right to Opt-Out of the Sale or Sharing of Personal Information: You have the right to opt-out of the “sale” or “sharing” of your personal information. Please note, however, that we do not “sell” or “share” the personal information of our job applicants or employees as those terms are defined under the CPRA.
Right to Restrict the Processing of Sensitive Personal Information: You have the right to restrict how we use and disclose sensitive personal information that we hold about you.
Anti-Retaliation Right: We are prohibited from discriminating against you for exercising any of the above rights.
Right to Designate an Authorized Agent: If you submit a request to know or delete your personal information through the use of an authorized agent, we may require that you (i) provide the authorized agent written permission to act on your behalf, and (ii) verify their identity directly with us. 

To exercise the rights described above, please submit a request to us by using the methods outlined below. 

In order to fulfill your request, we may need you to (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information related to you.  

We will confirm receipt of your request within then (10) business days of its receipt, and endeavor to respond within forty-five (45) calendar days of its receipt. If we require more time, we will notify you of the extension and provide an explanation of the reason for the extension in writing, and we will provide you with a response no later than ninety (90) calendar days of receipt of the request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We may charge a reasonable fee to processor respond to your requests if they are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for this decision and provide you with a cost estimate before completing your request. 

This CPRA Job Applicant Privacy Notice (the “Notice”) is effective as of the date of the “Last Update” stated at the top of this Notice. We may change this Notice from time to time with or without notice to you. By engaging or interacting with us after we make any such changes to this Notice, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, and without prejudice to the foregoing, our use of your personal information is governed by the Notice in current effect. Please refer back to this Notice on a regular basis. To view our Employee Privacy Policy, please contact hr@castleoaklp.com. If you have any questions about this Notice, want to exercise your rights, or need to access this Notice in an alternative format due to having a disability, please contact hr@castleoaklp.com or (646) 521-6700
 

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