(12/12/2014)

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

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, and employer’s address so that we can identify you and review certain activities that you may conduct on our website. In addition, we collect other personal information to enable us to provide you with services that are designed to meet your needs, such as check writing.

We maintain physical, electronic, and procedural safeguards 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 will be available on a secure portion of our website. You must log in under your unique username and password to view your personal and financial data.

We protect the transmission of information from your computer to ours through encryption. You cannot gain access to our website unless you are using an up-to-date browser with a minimum of 128 bit encryption.

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 this information secure and do not use it for any other purpose. Sometimes, we must share your personal and financial information with other service providers. 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 Office of Foreign Assets Control or any other government list. Whenever we share information about you and your account with an outside vendor, we require the vendor to keep your information confidential. They may not use it for their own purposes.

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 subpoenas, warrants, or orders.

We use aggregated information to continue to improve our website and to provide you with 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.

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 information for varying periods of time, typically ranging from three to six years. In addition, it is customary for brokerages, as a prudent business practice, to 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 use email to notify you of activity in your account or of new features, products or services that may affect the way you 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 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 security 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 sent to us through email.

Changes to Personal Information

Most information—your password, mailing address, email address—can be changed on the Settings page. We will send you an email to confirm that you have changed any personal information. We do not enable users to change their name, date of birth, social security number (SSN), or username. While you cannot change your username you can close your account and open a new account with a new username. If you need to change your name, date of birth, or SSN, contact us.

Cookies and Do Not Track Requests

Our website uses cookies (small data files that are stored by your browser on your computer). We use cookies so that our computers can keep the instructions you send in their proper order. If you set your browser to reject cookies, you will not be able to use our website. Use of do-not-track mechanisms that may be built into your web browser are not supported, and your use of a do-not-track mechanism will not disable activity tracking on our website.

We do not collect personal information about your activities at or from third-party websites or services and we do not permit third-parties to collect personal information about your use of our website.

Log Files

Our website automatically collects log files based on information available to us when you use our website. For example, we collect browser types to ensure that our website performs well for different browsers. We collect access times for regulatory reasons and to continually improve the design and operation of our website. We limit access to this information and keep it confidential, except as we determine necessary to properly maintain your account or as required by law. As a security precaution we collect website user IP addresses.

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

We will notify account holders prior to implementation of any material changes in our privacy policy by email or by a personalized 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. Our website will not allow users to open accounts if they indicate they are under 18. We take steps to verify the identity and age of account applicants, which involves passing personal information to certain vendors.

Links

We 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. You should read the privacy policy of any website 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, 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.