REGULATIONS REGARDING YOUR PERSONAL INFORMATION
Federal and state laws exists that regulates how we collect, use and safeguard your personal information. Before a company can disclose your personal information that you have entrusted with them, they are required to notify you in advance of the disclosure arrangement, and to give you ample time to opt-out.
It is our desire to keep you informed of changes in federal, state or self-regulatory organization rules and regulations that may have an impact on how we conduct our business and manage your personal information.
OUR COMMITMENT TO YOUR PRIVACY
We understand the importance of maintaining the privacy of your personal information. By entrusting us with your information, we would like to assure you of our commitment to keeping it private. We have taken reasonable measurable steps to protect the confidentiality, security and integrity of your information.
We do not sell, license, lease or otherwise disclose your personal information to third-party marketers for any purpose. Our commitment to the privacy of your personal information extends to both current and former clients, except as permitted or required by law or to improve our services.
YOUR PERSONAL INFORMATION
We collect personal information to open your account, determine your eligibility to trade certain asset classes, to process your transactions, to administer your account, to verify your identity, to update your account records, creditworthiness, to inform you of other products and services that may be of interest to you, carry out your request for other products and services, and to ensure compliance with appropriate federal and state laws.
The type of personal information collected varies according to the products or services provided and may include, the following categories: (1) name, (2) current and prior resident addresses, (3)telephone and fax numbers, (4) e-mail address, (5) social security number, (6) securities, futures or forex trading history, (7) date of birth, (8) banking relationships, (9) interest in opening an account, (10) investment experience, (11) total assets, (12) cash balances, (13) margin information, (14) trading positions, (15) account balances, (16) annual income, (17) net worth (18) excess margin, (19) margin loan records, (20) deposit and withdrawal history, and (21) employer name and address.
Affiliated companies are those under common ownership or common control. The term “control” refers to the ability to exercise a controlling influence over the management or policies of a company whether through (1) financial ownership; (2) contract; or (3) otherwise.
We will disclose information to affiliates if the information is required to provide a product or service you have requested. Additionally, we may disclose information to our affiliates about our experiences or transactions with you or your account in order to make you aware of services and products from which you may benefit. Information that may be disclosed to affiliates include your name, e-mail address, mailing address, date of birth, employment status, general account and demographic information and account history with us.
Our parent company is MBT Holdings, LLC, and MB Trading, MB Trading Futures, Inc., and WGAL, LLC (d/b/a Wizetrade), are affiliates of each other.
Our affiliated companies also understand the importance of maintaining the privacy and confidentiality of your personal information, and will not sell, license, lease or otherwise disclose your personal information to third-party marketers for any purpose.
Nonaffiliated companies are not under common ownership or common control, and are considered third parties under federal and state privacy laws.
We do not disclose your information to nonaffiliated companies unless (1) to facilitate your written requests or instructions; or (2) it is permitted or otherwise required by law. Examples of "permitted by law" include our clearing firms: Apex Clearing Corporation (which clears and settles your securities transactions); KCG Futures, a division of Knight Capital Americas, LLC (which clears and settles your futures transactions); credit bureaus (e.g., Experian, Equifax, and Trans Union); improvement of services provided to you; (2) to carry out your request or instructions; and (3) obtain quote data from securities and futures exchanges. Examples of "required by law" include regulatory investigations by SEC, FINRA, CFTC and NFA, federal and state investigative agencies, court orders or subpoenas, and the IRS.
We also prohibit the nonaffiliated companies from using or disclosing your information except for the limited purpose, and to the persons for whom disclosure was intended.
For purposes of printing and bulk mail distribution, we will disclose your name, resident address, e-mail address, and telephone number to third parties such as US Postal Service, UPS, Federal Express, and other similar private printing and distribution services.
All nonaffiliated companies with which we disclose your personal information agree to protect the information in a manner similar to the way we protect your personal information. We regularly review privacy policies of third parties for administrative services to ensure compliance with appropriate federal and state laws.
Joint marketing is a formal agreement between nonaffiliated companies that together will market their products or services to you.
We do not conduct joint marketing programs or disclose your personal information to nonaffiliated companies for marketing purposes.
Federal and state privacy laws requires us (1) to notify you and (2) obtain your consent prior to the disclosure of your personal information to nonaffiliated companies in a joint marketing program unless other permitted by law. Therefore, we will obtain your consent before disclosing your personal information to a nonaffiliated company that offers other financial products and services believed to be of interest to you.
ACCESS TO YOUR PERSONAL INFORMATION
Our employees and certain nonaffiliated companies have access to your personal information only on a "need to know" basis through access to sources including the following:
- Your account application or other supplemental account forms.
- Your transactional history with affiliates MB Trading, MB Trading Futures, Inc. and/or WGAL, LLC.
- Your account records including transactional history with nonaffiliated companies Apex Clearing Corporation and KCG Futures LLC, where it is appropriate
- Information from credit reporting agencies (e.g., Experian, Equifax, and Trans Union).
- Current and prior employers, federal and state agencies.
- Consumer reporting agencies such as McDonald Information Service, Inc., The GB Group Ltd., and Equifax’s Compliance Data Center and eID Compare.
We conduct regular internal audits to ensure that business practices and procedures are reasonably designed to ensure the confidentiality and access to your personal information is protected.
PROTECTION OF YOUR PERSONAL INFORMATION
We limit access to only those employees that need to know the information in order to assist in carrying out your request for products or services. We have policies and procedures that give direction to employees, and representatives acting on our behalf, regarding how to protect and use personal information.
We maintain reasonable physical, electronic, and procedural safeguards that comply with federal and state laws to protect your personal information. We place your account information on the secure portion of our website, using firewalls and other security technology to protect our network and systems from external attacks, and we require you to enter a unique user name and password to access your account information online. Our servers are enabled with SSL technology to prevent unauthorized parties from viewing personal information that you provide or access during a secure session. In addition, if you access information online, we use digital certificate services to authenticate that you are transacting with our website and not the website of an impostor.
We value your trust in our ability to safeguard your personal information. Therefore, we ccontinually review our security procedures and mechanisms to ensure that reasonable safeguards are in place to protect your personal information.
OPT OUT OF DISCLOSURE
Federal and state law allow you the opportunity to "opt out" of arrangements under certain circumstances in which your personal information would be disclosed to nonaffiliated companies or marketers.
We do not currently disclose information about you with nonaffiliated companies or marketers that triggers this opt-out right. Therefore, there is no need for you to opt out. If in the future we desire to disclose your personal information in a way that is inconsistent with this policy, we will notify you in advance and provide you with the opportunity to opt out of such disclosure through one of the options listed below.
If you elect to opt-out of disclosure, it will remain in force until you tell us to change your choice or for at least five (5) years from when you tell us your choice. Once that period expires, you will receive a renewal notice that will allow you to continue to opt-out of disclosure for at least another five (5) years. You can opt back in at any time.
To opt-out of a sharing arrangement, you can:
- Contact our Client Services Department at (866) 628-3001;
- Login to the secured client area of our website, and send a ticket to our Client Services team to “Opt-Out of Disclosure”;
- Send an e-mail through the secured client area of our website to [email protected] with the words "Opt-Out of Disclosure" in the subject line and your MBT account number in the body copy; or
- mail a letter to us indicating your desire to Opt-Out of Disclosure and your MBT account number.
An opt-out election (1) must be made for each account you maintain with us; (2) made by one account owner of a Joint account is applicable to all account owners of the Joint account; and (3) will not apply to communications required to service your account.
Our website contains links to strategic partners and other nonaffiliated companies that we believe may be of interest to you. However, we are not responsible for their privacy and security practices or the content of their websites.
STATE SPECIFIC NOTIFICATIONS
For Nevada Residents: Nevada Statute allows marketing calls to existing clients who are listed on the National Do Not Call Registry. If you prefer not to receive marketing calls from us, you can be placed on our Internal Do Not Call List by calling our Client Services Department or sending us a letter or e-mail.
You may also contact the Nevada Attorney General's office for additional information:
Bureau of Consumer Protection Office of the Nevada Attorney General
555 E. Washington Street, Suite 3900
Las Vegas, NV 89101
Phone: (702) 486-3132
Email: [email protected]
For Vermont Residents: We will not disclose information about your creditworthiness with our affiliates without your authorization or consent, but we may disclose information about our transactions or experiences with you with our affiliates without your consent.
Did you know that millions of consumers are sent hundreds of pieces of unsolicited commercial advertisement through the mail or contacted by telephone each year? The companies that make use of this type of service are called direct marketers and telemarketers. Many of these companies are members of The Direct Marketing Association (DMA); the oldest and largest trade association for users and suppliers in the direct, database and interactive marketing fields.
If you do not want to receive any commercial communications from the DMA in the future, you can call their Customer Service Department at (212) 768-7277, by sending an e-mail to [email protected], or by writing to the mailing address below and request opt-out.
The Direct Marketing Association
Attn: Customer Service, Opt Out
1120 Avenue of the Americas
New York, NY 10036-6700
When contacting the DMA, please be sure to include complete information about each name, resident address, and telephone number that you would like to have excluded from their national contact lists. If you have moved within the past year, you should also include your old address and phone number. This is also true for name changes and the resident addresses and telephone numbers associated with each name.
Direct marketing is e-mail, resident mail and telephone marketing. Your telephone and resident mail opt-out choices will last for five (5) years, subject to applicable law. Even if you limit direct marketing, we can still contact you to service your account or as otherwise allowed by federal or state law.
CLIENT SERVICES DEPARTMENT
THIS PRIVACY NOTICE IS PROVIDED TO YOU FOR INFORMATIONAL PURPOSES ONLY. YOU DO NOT NEED TO CALL OR TAKE ANY ACTION IN RESPONSE TO THIS NOTICE. WE RECOMMEND THAT YOU READ AND RETAIN THIS NOTICE FOR YOUR PERSONAL RECORDS.
Effective date: December 24, 2013