Randazzo Capital Management's policy is to comply with applicable state and federal regulation with respect to the protection of the nonpublic personal information of its clients. Consequently, to safeguard clients’ nonpublic personal information, Randazzo Capital has adopted various physical, electronic, and procedural measures, which are detailed below. 

In the course of regular business activity, clients provide personal information about themselves and other family members. Randazzo Capital respects and protects each client’s right to privacy. No Supervised Person may disclose nonpublic personal information about clients to any third-party, including affiliates, except as required or permitted by law and to carry out the services provided to those clients. Any violation of this policy must be reported to the CEO immediately.  

Definitions

For purposes of this policy, the terms “Client” and “Confidential Information” have the following definitions:

“Client” means:

1. An individual with a specific and continuous relationship with Randazzo Capital who obtains or has obtained a financial product or service from us used primarily for personal, family or household purposes; or

2. That individual’s designated representative.

“Confidential Information” is personally identifiable private information (information not available from public sources such as the phone book or a website) about the client or consumer, including information regarding name and address, age, social security number, assets, income, net-worth, account balance, account number, bank account information, beneficiary information and investment activity (such as purchase and redemption history).

Privacy Notice

In accordance with applicable state and federal laws, Randazzo Capital has adopted a written Privacy Notice and Privacy Policies and Procedures to ensure the protection of nonpublic client information. RCM’s Privacy Notice is included in Part 2 of Form ADV.

The CEO will review the Firm’s Privacy Notice and Privacy Policies and Procedures at least annually to ensure that they remain current and accurate. If changes are made to the Privacy Notice, the CEO or designee will be responsible for promptly sending a copy of the new Notice to each client.  

Initial Delivery

Randazzo Capital will make its written Privacy Notice available to each new client no later than at the time the client signs Randazzo Capital’s Agreement. Client’s acknowledgment of the availability of RCM’s Privacy Notice will be documented on the Agreement. 

Opt-out Rights

Randazzo Capital only shares nonpublic personal information as permitted by the GLBA under those circumstances that do not require the Firm to provide clients with notice and opt-out rights.

Change Notification

If changes are made to the Firm’s policies and procedures with regard to disclosing nonpublic personal information, the CEO or designee will be responsible for promptly sending a copy of the new Notice to each client. The CEO will maintain evidence of each such mailing in a designated file as part of the Firm’s books and records.