CLEARTRADE COMMODITIES PRIVACY POLICY

Your Privacy is Our Priority

ClearTrade, Inc. is committed to safeguarding the personal information that you provide us. This Privacy Policy describes how we handle and protect personal information we collect about individuals, such as you, who apply for or receive our products and services. The provisions of this notice apply to former customers as well as our current customers.

Why and How We Collect Personal Information

When you apply for or maintain an account with ClearTrade, we collect personal information about you for business purposes, such as evaluating your financial needs, processing your requests and transactions, informing you about products and services that may be of interest to you, and providing customer service. The personal information we collect about you includes:

information you provide to us on applications and other forms, such as your name, address, date of birth, social security number, occupation, assets, and income;

information about your transactions with us;

information we receive from consumer reporting agencies, such as your credit history and creditworthiness, and other entities not affiliated with ClearTrade; and

information you provide to us to verify your identity, such as a passport, or received from other entities not affiliated with ClearTrade.

How We Protect Personal Information

We limit access to your personal information to those employees who need to know in order to conduct our business, service your account, and help you accomplish your financial objectives, such as providing you with a broad range of products and services. Our employees are required to maintain and protect the confidentiality of your personal information and must follow established procedures to do so. We maintain physical and procedural safeguards to protect your personal information. We do not rent or sell your name or personal information to anyone.

Disclosure to Non-Affiliated Third Parties

In order to support the financial products and services we provide to you, we may share the personal information described above with third-party service providers and joint marketers not affiliated with us, including:

financial service institutions (e.g., advisers, dealers, brokers, trust companies and banks) with whom we have joint marketing agreements, such as agreements to market financial services or products that we jointly offer, endorse or sponsor; and

companies under contract to perform services for us or on our behalf, such as vendors that prepare and mail statements and transaction confirmations or provide data processing, computer software maintenance and development, transaction processing and marketing services.

These companies acting on our behalf are required to keep your personal information confidential.

Also, we may disclose personal information with non-affiliated companies and regulatory authorities as permitted or required by applicable law. For example, we may disclose personal information to cooperate with regulatory authorities and law enforcement agencies to comply with subpoenas or other official requests, and as necessary to protect our rights or property. Except as described in this privacy policy, we will not use your personal information for any other purpose unless we describe how such information will be used at the time you disclose it to us or we obtain your permission to do so.

Accessing and Revisiting Your Personal Information

We endeavor to keep our customer files complete and accurate. We will give you reasonable access to the information we have about you. Most of this information is contained in account statements that you receive from us and applications that you submit to obtain our products and services. We encourage you to review this information and notify us if you believe any information should be corrected or updated. If you have a question or concern about your personal information or this privacy notice, please contact your ClearTrade representative.

RIGHT TO OPT OUT OF INFORMATION SHARING

If you prefer that we not disclose your Personal Information to unaffiliated third parties, you may opt out of those disclosures. That is, you may direct us not to make those disclosures (other than disclosures permitted or required by law). You, however, may not opt out of Personal Information disclosed about you to your Introducing Broker (if applicable), or any service provider necessary to effect or process any transaction in your account(s) with us (if applicable). If you wish to opt out of disclosure to nonaffiliated third parties, you may email us at research@cleartrade.com, stating that you wish to opt out of all information sharing of your Personal Information.

JOINT ACCOUNT/PARNERSHIP PROCEDURES

In the event you have an MF Global account, and if your account(s) with us is for joint tenants with rights of survivorship, tenants in common, or a general partnership, any one party to the account may elect to opt out for the account. That opt out election will bind all parties to the account.

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