Emerald Capital Management Privacy Policy

Emerald Capital Management is required to communicate its position as it pertains to the privacy of customer information. We are committed to ensuring the privacy and confidentiality of information you provide to us, which enables us to provide the financial services you require. Please take a moment to review our privacy policy, as described below.

How and Why We Obtain Information

In order to facilitate the servicing of your account, Emerald Capital Management may receive nonpublic personal information about you from any of the following sources:

• From your applications or forms (examples may include name, address, Social Security number, date of birth, assets and income) or from supporting account documentation or correspondence.

• From transactional activity in your account (examples may include trading history and balances).

• From verification services and consumer reporting agencies (to ensure the accuracy of application data, or to assess creditworthiness if you apply for credit products).

• From other sources with your consent or with the consent you give to your representative (for example, from other institutions if you transfer positions or assets into a clearing firm).

How We Protect Your Information

Emerald Capital Management has always considered the protection of sensitive information to be a sound business practice and a foundation of customer trust. We employ extensive information protection controls in keeping with industry standards and practices, and we regularly adapt these physical, electronic and procedural controls to respond to changing requirements and advances in technology.

Within Emerald Capital Management and among our service providers, we restrict access to your information to those who require that access in order to provide products and services to you. We may share the personal information that we collect about our customers, prospects or former customers with our registered representatives or with:

• Unaffiliated service providers (for example, a clearing firm and its affiliated entities, our data processing provider and securities clearinghouses) as necessary to complete your transactions.

• Government agencies and law enforcement officials (for example, for tax reporting or under court order).

• Other organizations, as required by the laws that protect your privacy (such as for fraud prevention).

• Other organizations, as directed by you (for example, if you request personalized performance reporting).

Privacy Online

Emerald Capital Management considers privacy, security and service to be just as critical in the online environment as in the rest of our operation. We therefore employ all of the safeguards described above, along with the following internet-specific practices. Emerald Capital Management uses a variety of proven protections to maintain the security of your online session. For example, we make extensive use of firewall barriers, encryption techniques and authentication procedures. We also use cookies and similar files that may be placed on your hard drive for security purposes, to facilitate site navigation and to personalize the appearance of our site.

When you visit Emerald Capital Management’ internet sites, we may collect technical and navigational information, such as computer browser type, internet protocol address, pages visited and average time spent on our web sites. This information may be used, for example, to alert you to compatibility issues, or it may be analyzed to improve our web design and functionality.

 

Your Connection to Emerald Capital Management

For your convenience, we offer several options for accessing your account information. You can review your information independently using your statements, or through our internet services. You may also e-mail, write, or call us with your requests for information.

If you are a former customer, your information is treated in the same manner as the information of current customers.