Protecting the privacy and safeguarding the personal
and financial information of our clients and Web site visitors is one of our
highest priorities. The following Privacy Statement explains how we collect and
protect your information. By opening an account or by using our Web site, you
give your consent to the collection and use of personal information by us as
explained in this privacy statement.
Collection of personal information
We collect information required to open an account, to transact
business effectively and to safeguard your assets and your privacy. To do
this, we gather information to help us assess your needs and preferences.
The information we collect directly from you includes
information required to communicate with you, including your name, mailing
address, telephone number, e-mail address and to identify who you are. We also
collect demographic information when you open an account, including, birth date,
education, occupation, etc. We also assess your trading experience, your
approximate annual income and approximate net worth to assess your financial
position.
Usage of personal information
We use personal information only as appropriate to provide you
quality service and security. For example, we may use the information collected
from you to verify your identity and contact information. We may also use this
information to establish and set up your trading account, issue an account
number and a secure password, maintain your account activity, and contact you
with account information. This information helps us improve our services to you,
customize your browsing experience and inform you about additional products,
services or promotions that may be of interest to you.
Our affiliates and partners
We may share information with affiliates if the information is
required to provide the product or service you have requested or to provide you
the opportunity to participate in the products or services our affiliates offer.
We may also forge partnerships and alliances, which may include joint marketing
agreements, with other companies who offer high-quality products and services
that might be of value to our clients. In order to ensure that these products
and services meet your needs and are delivered in a manner that is useful and
relevant, we may share some information with partners, affiliates and alliances.
This allows them to better understand the offers that are most relevant and
useful. The use of your personal information is limited to the purposes
identified in our relationship with the partner or affiliate.
Non-affiliated third parties
We do not sell, license, lease or otherwise disclose your
personal information to any third party for any reason, except as described
below.
We reserve the right to disclose your personal information to
third parties where required by law to regulatory, law enforcement or other
government authorities. We may also disclose your information as necessary to
credit reporting or collection agencies, or when necessary to protect our rights
or property.
To help us improve our services to you, we may engage another
business to help us to carry out certain internal functions such as account
processing, fulfillment, client service, client satisfaction surveys or other
data collection activities relevant to our business. We may also provide a party
with client information from our database to help us to analyze and identify
client needs and notify clients of product and service offerings. Use of the
information shared is strictly limited to the performance of the task we request
and for no other purpose. All third parties with which we share personal
information are required to protect personal information in a manner similar to
the way we protect personal information.
Restriction of responsibility
If at any time you choose to purchase a product or service
offered by another company, any personal information you share with that company
will no longer be controlled under our Privacy Statement. We are not responsible
for the privacy policies or the content of sites we link to and have no control
of the use or protection of information provided by you or collected by those
sites. Whenever you elect to link to a co-branded Web site or to a linked Web
site, you may be asked to provide registration or other information. Please note
that the information you are providing is going to a third party, and you should
familiarize yourself with the privacy policy provided by that
third party.
Opting out of disclosures of non-public personal
information
You may direct us not to disclose non-public personal
information to certain non-affiliated third parties. To opt out of sharing
non-public personal information with non-affiliated third parties, please
contact a client service representative. An opt out election made by one account
owner of a joint account is applicable to all account owners of the joint
account. An opt-out election must be made for each separate account you hold
with us.
Use of "cookies"
We use cookies to assist us in securing your trading activities and to enhance the
performance of our Web site. (Cookies are small text files sent from the Web
server to your computer.) Cookies used by us do not contain any personal
information nor do they contain account or password information. They merely
allow the site to recognize that a page request comes from someone who has
already logged on.
We may share Web site usage information about visitors to the
Web site with reputable advertising companies for targeting our Internet banner
advertisements on this site and other sites. For this purpose, pixel tags (also
called clear gifs or web beacons) may be used to note the pages you"ve visited.
The information collected by the advertising company through the use of these
pixel tags is not personally identifiable.
To administer and improve our Web site, we may use a third
party to track and analyze usage and statistical volume information, including
page requests, form requests, and click paths. The third party may use cookies
to track behavior and may set cookies on behalf of us. These cookies do not
contain any personally identifiable information.
Communications
Unless otherwise indicated for a particular service, any
communications or material of any kind that you e-mail or otherwise transmit
through the services, including information, data, questions, comments or
suggestions (your "Communications") will be treated as non-proprietary and
non-confidential.
By accepting this Agreement you grant a license to us to use
your Communications in any way we think fit, either on the Web site or
elsewhere, with no liability or obligation to you. We are free to use any idea,
concept, know-how or technique or information contained in your Communications
for any purpose including, but not limited to, developing and marketing
products.
We are entitled, but not obligated, to review or retain your
Communications. We may monitor your Communications to evaluate the quality
of service you receive, your compliance with this Agreement, the security of the
Web site, or for other reasons. You agree that such monitoring activities will
not entitle you to any cause of action or other right with respect to the manner
in which we monitor your Communications. In no event we will be liable for any
costs, damages, expenses or any other liabilities incurred by you as a result of
our monitoring activities.
Changes to this Privacy Statement
From time to time, we may update this Privacy Statement. In the
event we materially change this Privacy Statement, the revised Privacy Statement
will promptly be posted to the Web sites and we will post a notice on our Web
sites informing you of such changes. You agree to accept posting of a revised
Privacy Statement electronically on the Web site as actual notice to you. Any
dispute over our Privacy Policy Statement is subject to this
notice and our Customer Agreement. We encourage you to periodically check back
and review this policy so that you always will know what information we collect,
how we use it, and to whom we disclose it. If you have any questions that
this statement does not address, please contact a Client Services
representative.
