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Privacy Policy

(12/19/2019)

We respect the confidentiality of our customers’ personal information. We realize that online privacy is extremely important and we appreciate the trust you have placed in us. We are making our Privacy Policy available to you to remind you of our concern for and our efforts to protect your personal information.

Personal Information

Federal securities and anti-money laundering laws require us to collect and verify personal information of our clients such as name, address, age, date of birth, social security number (SSN), employer, employer’s address, income and net worth, and in certain instances, a driver’s license or passport so that we can identify you and review certain activities that you may conduct on our website. In addition, in certain circumstances we may ask for other personal and financial information in order to permit you to invest in privately placed securities or provide you with access to other brokerage services we may offer. Your personal information includes transactional data we have collected through your use of our website(s) such as transaction history and performance. We collect other information to enable us to provide you with optional services we offer that you may choose to use. For example, if you wish to transfer money into your account through an electronic funds transfer, we ask you for information about your bank account. We keep all such personal information secure and do not use it for any purpose other than what we disclose to you.

We maintain physical, technical and administrative controls in keeping with securities industry standards and practices that are designed to protect your personal and financial information. We review and adjust these safeguards as necessary in response to customary practices in the securities industry. Your account information is only available on the portions of our website that are accessed after a login using our security protocols.

We protect the transmission of information from your computer to ours through encryption. To gain access to our website you must use a browser with a minimum of 128-bit encryption and secure cipher.

The transmission of information via the Internet is not completely secure. Although we do our best to protect your nonpublic, personally identifiable information, we cannot guarantee complete security of your nonpublic, personally identifiable information transmitted to our website. Any transmission of such information is at your own risk.

Information Sharing

We do not share personal information about our customers with unaffiliated third parties for the purpose of marketing their products and/or services. Sometimes, however, we must share your personal and financial information for everyday business purposes such as to process transactions or maintain account(s), or as otherwise permitted by law or regulation. For example, we use outside vendors to keep your cash deposits and provide you with checking services. These vendors must have information about you and your account to provide these services. As another example, to prevent our website from being used by money launderers, we use one or more vendors to verify the identity of each account applicant and to verify that the applicant is not flagged by the Department of the Treasury Office of Foreign Assets Control or identified on any other government list that would prohibit us or limit our ability to do business with you, which information may be shared with other financial institutions with which you do business so that they may comply with their legal and/or regulatory obligations. Whenever we share information about you and your account with an outside vendor, we require the vendor to keep your information confidential and prohibit use for their own purposes.

Based on the nature of your relationship with us, we may exchange information with other third parties. If we provide workplace services to your employer or plan sponsor, we may exchange any information received in connection with such services with your employer or plan sponsor or others they may authorize. If you conduct business with us through your investment professional, we may exchange information we collect with your investment professional or with others they may authorize. If you access our services through an introducing broker who uses us to provide clearing services we may exchange information we collect with the representative who services your account and personnel at the introducing broker so they can provide services to you.

As required by law, we will also provide your information to the Internal Revenue Service, the Securities and Exchange Commission (SEC), other regulatory or government entities, or as otherwise required pursuant to judicial or other government requests for information, subpoenas, warrants, or orders.

We use aggregated information to continue to improve our website and to provide innovative financial services. We may share such aggregated information with our customers, affiliates, vendors, product and information providers, or other individuals or entities for commercial or academic purposes. Aggregated information is information about our customers in general or about groups of customers in general. Aggregated information does not identify the personal or financial information of any individual customer.

Because we do not currently share your personal information with any affiliated or non-affiliated third party for marketing purposes, there is no need at this time for you to opt-out or take any other action telling us not to share such information.

SEC Registered Self-Clearing Broker/Dealer

We are a registered self-clearing broker/dealer and must comply with SEC regulations. The SEC requires us to keep different types of customer information for varying periods of time, typically ranging from three to six years. In addition, as a prudent business practice, we keep some information for longer periods of time so that the needs of customers and the brokerage are met.

Use of Email

We keep our costs, and your costs, down by using email to communicate with you. For example, we will email you to tell you that your monthly statement is available on our website and to send you other legally required notices. We also may use email to notify you of activity in your account or of new features, products or services that may affect the way you may be able to use the website. We will not, however, transmit confidential financial information through email.

We deliver all account alert emails to your Message Center on our website and, by default, we may also send copies of all emails to the primary email address associated with your account. You can instruct us not to send copies of emails to your primary email address, except for certain alerts, by changing the Notification Settings in your Message Center.

Messages sent to us through the Contact Us page on our website are secured with the same technology we use for account information. We cannot guarantee the security of messages you send directly to us addressed to our various email domains.

Tell-a-Friend

We collect your name and email address, as well as the name and email address of your friend if you use our Tell-a-Friend feature. The email we send your friend will identify you as the sender. We may send both you and your friend follow-up promotional messages.

Changes to Privacy Policy

Account holders will be notified prior to implementation of any material changes in our privacy policy by email or by a message that can appear on the login screen.

Information for Users Under 18

We do not open accounts for people under the age of 18 unless the account is a guardianship or other trust account. We take steps to verify the identity and age of account applicants, which involves passing personal information to certain vendors as described above.

Information Concerning State Laws

The California Consumer Privacy Act of 2018 (the CCPA) provides California residents — as that term is defined in Title 18, Section 17014 of the California Code of Regulations — the right to request that we delete any personal information that we have collected from you. However, please note that, as described above, we are subject to recordkeeping requirements imposed by the SEC and the Financial Industry Regulatory Authority, Inc. (FINRA) that preempt this law and prevent us from deleting your information. For example, we cannot delete your information if your request is made while you are a client or at any time within 6 years after you have closed your account. Consequently, although you have the right to submit your request we will be required to deny it under those circumstances. You may submit a request by accessing your account online and sending us a written request through the Contact Us page. If you cannot access your account, then you or an authorized agent may submit your request by sending us a written request that includes proof of your identity (such as a photocopy or scanned image of a current photo driver’s license or other form of government identification) and address (such as a copy of a current utility bill). You may also submit your request by calling us

The CCPA also gives its residents certain other rights, including to request details about what we have collected about you, to direct us not to sell your information and to not receive discriminatory treatment from us by exercising your rights under the CCPA. We already disclose much of what we collect about you and why when you access your account online and in this Privacy Policy. In addition, as noted above, we do not share personal information about our customers with unaffiliated third parties for the purpose of marketing their products and/or services. You may contact us with any questions through the Contact Us page on our website.

Links

We may make links to other unrelated third-party websites available so you can easily access relevant information or enhance your experience as a customer. This privacy policy applies only to the use of our website(s). You should read the privacy policy of any other website you use or that you link to, because the use of any personal information you provide to them will be governed by their separate privacy policy. Our provision of links to unrelated third-party websites is not an endorsement or adoption of the website, or the business practices, or information contained on such websites.

Questions About Our Privacy Policy

If you have additional questions or concerns about our privacy policy, contact us.