Privacy Policy

The Company, as a member of the financial services industry, has been and continues to be subject to laws and regulations regarding the collection and exchange of nonpublic personal information about the client. Clients that choose to invest with the Company will provide the Company with certain personal information about the clients. The Company collects personal information from customers to the extent necessary to enable the Company to perform services. The following information may be collected:

1. Information provided as a result of completion of customer account agreements and other related documents and forms provided at the time or subsequent to the account review and approval process;
2. Information available as a result of transactions with the Company;
3. Information that the Company receives from outside entities, including consumer reporting agencies, relating to the application approval process; and
4. Information the Company may obtain as a result of the customers use of the Company website and other online services. Such information may be available by the utilization of a user ID and password assigned by the Company or from a Company “cookie” or OEC service provider’s cookie. The Company will use this information to evaluate traffic patterns on the site. The Company will not use this information for any other purpose.

Personal Information Limitations and Retention

Personal information is retained and disclosed only as necessary to serve our customers. Such personal information about current and former customers is only used or disclosed to third parties in the following limited circumstances, and in accordance with applicable law:

1. As required to process or service customer account or transactions (wire transfers, withdrawals, etc.);
2. As permitted by law to our service providers, including those that perform marketing services on our behalf. The Company will monitor these providers and make reasonable efforts to ensure the privacy and security of your information;
3. As required by regulators, tax authorities and examiners, law enforcement personnel and/or in response to a subpoena or legal process whereby the Company believes that such disclosure is required;
4. As may be appropriate to protect against fraud or illegal activity, for the safety of customers, employees, or property, or is otherwise permitted by law; and
5. As the customer may disclose or specifically direct the Company to disclose on the customer’s behalf, personal information to a third party.

Protecting the Confidentiality and Security of Personal Information

The Company protects the confidentiality and security of personal information by implementing and maintaining appropriate security safeguards. Examples of our safeguards include:

1. Restricting access to personal information to those employees who need to know such information in order to provide products or services to customers; and
2. Maintaining physical, electronic, and procedural safeguards to protect personal information.

Notice

The Company will provide annual notices to its individual consumers who are customers regarding the Privacy Policy, and if there is any change to the Privacy Policy prior to the time that an annual notice would otherwise be provided, a revised privacy notice will be provided.