Privacy Policy

Compass Point Research & Trading, LLC respects your right to privacy. We have always been committed to securing the confidentiality and security of information we collect about our customers. Nonpublic information about you will not be shared with third parties without your consent, except for the specified purposes described below. This notice describes the information we may gather from you and the circumstances under which we may share it. We are proud of our privacy practices and want our current and prospective clients to understand what information we collect and how we use it.

Why We Collect Your Information – We gather information about you and your accounts so that we can (i) know who you are and thereby prevent unauthorized access to your information, (ii) design and improve the products and services we offer and (iii) comply with the laws and regulations that govern the financial industry.

What Information We Collect – We may collect the following types of ‘nonpublic personal information’ about you:

• Information about your identity, such as your name, address and tax identification number;
• Information about your transactions with us;
• Information we receive from you on applications, forms or through discussion.

Sources From Which We Obtain Your Information – We collect nonpublic personal information about Compass Point Research & Trading LLC clients such as you from the following sources:

• Information we receive from you on applications, forms or through discussion;
• Information we may obtain via the Internet;
• Information we receive from our clearing firm or third-party vendor for authentication purposes.

What Information We Disclose – Your securities account is carried by our clearing firm pursuant to clearing agreements. We may disclose to them all the information we collect regarding your account. Our clearing firm is contractually obligated to keep the information that we provide them confidential and use the information only for the services required and as allowed by applicable law or regulation.

We may also disclose information to third parties to effect a transaction you request or authorize, for example, to a bank from which you wish to purchase a certificate of deposit.

We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law and noted above. Moreover, we will not release information about our customers or former customers, except as noted above unless one of the following conditions is met:

• We receive your prior written consent.
• We believe the recipient to be you or your authorized representative.
• We are required by law or regulation to release information to the recipient.

What are my rights to opt out of disclosure – In certain circumstances, the law allows you to “opt out” of our sharing nonpublic personal information about you with affiliated and nonaffiliated companies; that is, you may direct us not to make such disclosures. Currently, we do not share information about you with any affiliate or third party that triggers this “opt out”; therefore, there is no need to “opt out”. If in the future we desire to disclose your 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.

Confidentiality And Security – We maintain physical, electronic and procedural safeguards to guard your personal account information. We also restrict access to your personal and financial data to authorized associates who have a need for these records. We require all nonaffiliated organizations to conform to our privacy standards and are contractually obligated to keep the information provided confidential and used as requested. Furthermore, we will continue to adhere to the privacy policies and practices described in this notice even after your account is closed or becomes inactive.

Protecting Your Information

There are a number of steps you can take to protect your information, including 1) before you reveal any personally identifying information, find out how it will be used and whether it will be shared with others; 2) pay attention to your billing cycles and follow up with creditors if your bills don’t arrive on time; 3) guard your mail from theft; 4) deposit outgoing mail in post office collection boxes or at your local post office; and, 5) put passwords on your credit card, bank and phone accounts. If you suspect that your personal information, including social security number or account information has been misappropriated to commit fraud or theft please contact: 1) your CPRT personal representative; 2) the fraud departments of each of the three major credit bureaus; 3) the creditors for any accounts that have been tampered with or opened fraudulently; and 4) your local police or the police in the community where the identify theft took place. You should also contact the Federal Trade Commission (FTC) at 1-877-IDTheft or at www.consumer.gov/idtheft.

Please be advised that this privacy notice is subject to change. In the event that changes occur, you will be informed in accordance with applicable laws. A copy of this privacy notice may also be obtained by contacting our office.