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Privacy Policy

Straits Financial LLC believes in the importance of your privacy.  And in order to preserve the integrity of the information you provide to us in opening an account with Straits or one of its affiliates (collectively “Straits”), we want you to understand how we work to protect your privacy.

Straits restricts access to personal information about its customers to only those personnel and affiliates who must have the information in order to provide the services you are seeking. It is also provided to meet regulatory and legal requirements.  In some cases, unaffiliated third parties will be supplied with personal information because their access to such information is permitted or required by law and they need to know such information in order to assist Straits in providing the products and services you receive from us. Lastly,  information  may  be  shared  with  unaffiliated  third  parties  whose  access  to  such information is necessary in order for Straits to engage in joint marketing efforts with such third parties.

In providing you with the financial services you seek, Straits may collect the following types of nonpublic personal information from you:  any information you may have included on your account application, including your name, address, social security number, any financial information about you; and, information regarding your trading or credit histories.

Straits does collect and store personal information about visitors to our website via the use of cookies.  We also collect the following; collect general site traffic information such as visitor, time of day, day of the week, browser, city, state, paths taken through our site, and search engine(s) used to find our site.

Rest assured that Straits will not sell your personal information to any third parties.  Your personal information will remain subject to the strictest confidentiality protections.  We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you.  Straits strives to use commercially reasonable safeguards to maintain confidentiality of your personal data.

To the extent that we use unaffiliated third parties for electronic services, such providers will be subject to strict contractual requirements to maintain the confidentiality of any customer information they may obtain in connection with their services.  Furthermore, we will disclose only the information necessary to provide such services.

In certain instances, legal authorities or regulatory agencies may require that we disclose certain customer information, which we will have the obligation to provide.  In addition, we may be forced to disclose information to enforce our legal rights, or in order to perform credit checks or collect debts.

General Data Protection Regulation Privacy Notice

Data protection privacy notice
We are committed to protecting your personal information and ensuring we respect your privacy. This Privacy Notice explains how we will look after and use any personal information that we collect about you.

What is personal information?
Personal information means any information about you from which you can be identified. Examples of personal information include your name, home address, date of birth, telephone number and e-mail address but it also includes other pieces of information which can be used to identify you, either directly or indirectly, such as a cookie.

Who we are
Straits Financial LLC is the Controller of the personal information you provide to us. If you have any questions about this Privacy Notice or the information we hold about you please contact our Chief Compliance Officer using the details set out below:

Full name of legal entity: Straits Financial LLC
Name relevant contact: James Gordon
Email address: jgordon@straitsfinancial.com & compliance@straitsfinancial.com
Postal address: 425 S. Financial Place, Suite 3990, Chicago, IL 60655
Contact telephone numbers: 312-846-5656

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would however appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

What types of information do we use?
We collect information in the course of providing our financial services to you. The information which we collect, use, store and transfer about you are:

a) First and last name, middle name, email address, home address, phone number and other contact information;
b) Date of Birth;
c) Tax filing status;
d) Tax Identification number;
e) Nationality or place of citizenship;
f) Employer, employment history and occupation;
g) Copies of identification documents such as, passport, driver’s license, state ID or other types of government issued identification;
h) as Ancillary information provided on a document used for proof of residential address;
i) Bank account information, such as routing and account numbers;
j) Financial information such as net worth, annual income and liquid assets;
k) Transaction, account activity, and trading experience history;
l) IP Addresses;
m) Recorded phone conversations;
n) Authorized signatory list, including signatures of your employees, agents, contractors, beneficial owners, and others associated with entities.

Our products and services are not intended for children and we will not knowingly collect any data related to children.

We do not collect any special categories of personal data. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic or biometric data.

Consequences of not providing some types of information
Where we need to collect your personal information by law, for regulatory purposes, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to provide the services you asked for. In this case we may deny to open or have to close your applicable trading account.

How do we collect information about you?
Typically we will collect information from you when you contact us directly or provide information to your broker in order for us to provide our products and services. We collect information from and about you in the following ways:

• Processing your application for an account
• Any managing or maintenance of your account with Straits
• When you sign up for our Marketing Materials
• When you visit our website
• When you complete Welcome Surveys or enter information into forms on our website
• Any other purposes which we notify you of at the time of obtaining your information.
• Through using our website when we collect information using cookies or similar technologies which tell us about your equipment, browsing actions and patterns.

Please note that we may be required to disclose your personal data to third parties in certain situations, including, without limitation, the following:

(a) cases in which the disclosure is required or authorized based on the applicable laws and/or regulations;
(b) cases in which the purpose of such disclosure is clearly in your interests;
(c) cases in which the disclosure is necessary for any investigation or proceedings, including enforcement of Straits legal rights;
(d) cases in which the personal data is disclosed to any officer of a prescribed law enforcement or regulatory agency;
(e) where such disclosure is permitted by applicable law.

The third parties which we share personal information with are as follows:

• Back office equity system providers
• Platform providers
• Third party vendors used to confirm information you provided during the account opening process.
• Online application hosting
• IT Vendors who back up information for operational and regulatory purposes

To the extent that we use unaffiliated third parties for services, such providers will be subject to strict contractual requirements to maintain the confidentiality of any customer information they may obtain in connection with their services. Furthermore, we will disclose only the information necessary to provide such services. Where we disclose your personal data to third parties, we will employ our best efforts to require such third parties to protect your personal data.

How we will use your personal information
We only obtain, use and keep personal information where we need it for a specific purpose. We set out in the table below the ways in which we plan to use your personal information. We are only able to use your personal information if we have a proper legal reason, regulatory request or basis for doing so. This is called a legal basis and the regulations require that we have a legal basis so that your privacy is protected. Most commonly we will use your information in the following ways:

• We have a contract with you. For example, we have agreed to provide financial services and hold your trading account for you and have a contractual agreement to do this.
• We have legal and regulatory obligations. We need to use your personal information to comply with laws that assist in the prevention of financial crime and to comply with regulatory obligations. For example this might include confirming your identity and source of wealth, as well as ensuring we provide you with necessary information so you understand the risk of the financial services we can provide.
• We have asked for, and you have provided, consent to use your information. Please note that you can withdraw your consent at any time – this is part of how the law protects your interests.
• We, or a third party, have a legitimate interest in processing the information and your interests and fundamental right do not override those interests. For example, processing your information to prevent fraud.

The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process (collectively, “the processes:) your personal data, including:

 Purpose  Lawful basis for processing including our legitimate interests
To on-board you as a new customer, including carrying out due diligence or other screening activities (including anti-money laundering, “know-your-client”, credit and background checks) in accordance with legal or regulatory obligations or Straits’ risk management procedures that may be required by law or that may have been put in place by Straits. To fulfil our contract with you.

To fulfil our legal obligations to prevent financial crime.
To manage your account, including but not limited to executing your instructions with respect to any  transactions, processing your orders, processing payments made to and from your account and executing your instructions with respect to the update of your company particulars. Necessary for our legitimate interests – to recover debts due to us.
To monitor your account on an on-going basis. To fulfil our contract with you.
To meet our regulatory obligations to provide you with regular information about your account and investment activity. To fulfil our regulatory obligations.
To contact you about other products and services we think you may be interested in and conducting research, analysis and development activities to improve Straits’ services and facilities in order to enhance your Account with Straits or for your benefit, or to improve any of Straits’ services for your benefit; Necessary for our legitimate interests – to develop our products and services and grow our business.
To use data to improve our website. Necessary for our legitimate interests – to understand how our customers interact with our website.
Carrying out your instructions or responding to any enquiry given (or purposed to be given by) us on your behalf. To fulfil our contract with you.
Prevent or investigate any fraud, unlawful activity or omission or misconduct, whether relating to your Account with Straits or any other matter arising from
your Account with Straits, and whether or not there is any suspicion of the aforementioned.
To fulfil our regulatory obligations
Complying with or as required by any request or direction of any governmental authority; or responding to requests for information from public agencies,
ministries, statutory boards or other similar authorities. For the avoidance of doubt, this means that Straits may/will disclosure the Individuals’ Personal Data to the aforementioned parties upon their request or direction.
To fulfil our regulatory obligations.
Complying with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including meeting the requirements to make disclosure under the requirements of any law binding on Straits and/or for the purposes of any guidelines issued by regulatory or
other authorities, whether in The United States of  America or elsewhere, with which Straits is expected to comply.
To fulfil our regulatory obligations.

Marketing
We will always seek your consent to use your personal information for this purpose. We will very clearly explain why we are seeking your consent and ensure that you are provided with a simple method of providing this – usually via tick box on our website.

You are free to change your mind at any time by info@straitsfinancial.com. We want to contact you about products or services we feel will be of interest to you or of benefit. We use your personal information to communicate with you if we have either your consent or a ‘legitimate interest’. We believe that as a commercial enterprise we do have a legitimate interest in contacting you about our products or services and we will only do so if we decide it would be of interest or beneficial for you. However, we will also gain your consent to do so. We will always ensure we seek consent from you in a way which is clear and explains why we are seeking consent to use your personal information. We will very clearly explain why we are seeking your consent and ensure that you are provided with a simple method of providing this – usually tick box via our website.

Third party marketing

We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.

Cookies
Cookies are small text files placed on your computer (or other device where you access the internet) used to collect information on your activities online. They can also be used as part of website functionality – for example if you use online service to access / your platform account and your trading account so you should be careful about accepting, deleting or removing them. We can collect information about the device you are using to access the internet, your IP address and website browser (for example). Cookies can tell us what information you were looking at, for how long, which internet sites interest you which are useful for us particularly for marketing our products and to ensure we are delivering the right service to clients.

If you have concerns about cookies this web site explains how you can delete and control the cookies that are stored on your computer: https://www.aboutcookies.org/

Who we share your information with
We may need to provide information to third parties for a variety of reasons. For example, we may need to provide information to assist in the detection or prevention of crime or for the purpose of safeguarding national security. Please refer to the table in the section ‘How we will use your personal information’ which explains how we use your data.

Third parties may include but are not limited to parties we share your information with to provide or facilitate goods and services to you such as back office equity system providers, platform providers, and third-party vendors used to confirm information you provided to us during the account opening process; IT vendors used to provide you or Straits with goods and services such as Straits online application hosting and development and vendors we use to backup information for operational and regulatory purposes; and auditors, regulators, and law enforcement. Straits does not process any special categories of data.

Sending your information outside of the EEA
The regulations which have been put in place to protect your privacy apply throughout the EEA. As explained in the section above we will send your information to other third parties who are based outside of the EEA, however we will only share your information with them because the following safeguards have been put in place:
• The country we send your information to is deemed to provide an adequate level of protection by the European Commission;
• The information is being transferred between organizations which are engaged in the same economic enterprise, or within our corporate group, and we have an agreement in place which sets out how your privacy will be protected;
• The entities we transfer your information to are based in the US and are part of the Privacy Shield which requires them to provide a similar level of protection to European standards.

We will ensure that we give full consideration to the GDPR requirements in relation to transfers of personal data outside of the EEA when we make operational changes.

You can obtain further information on the specific mechanism used by us when transferring your personal information outside of the EEA by contacting the Chief Compliance Officer.

Storing your information
As a financial services provider we will typically have a contract with you and will need to keep your personal information (updated to ensure accuracy) to fulfil our contract. We also need to comply with EU, UK, and US law, which often requires us to keep certain records - which will include certain personal information – for several years.

When we decide how long we will retain your personal information, we will take into account the amount, nature, sensitivity of your information and how we want to use it as well as the potential risk of harm being caused from unauthorized use or disclosure.

Straits will retain your personal data as long as it is needed for the purposes outlined in Section 3, including but not limited to retaining personal data after account closures as required by applicable law and regulations.

Your rights
You are provided with a number of different rights under the data protection laws in relation to your personal information. These allow you:

• To access your information;
• To request we correct your information;
• To request that we erase your information;
• To object to the processing of your information;
• To request a restriction in the processing of your information;
• To request a transfer of your information; and
• To withdraw your consent.

If you wish to exercise any of these rights please, contact your broker on your account. Please note that you will not have to pay a fee to access your personal information or to exercise any of the other rights. We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or we may refuse to deal with your request. We may also need to seek further information from you to confirm your identity before we release any personal information. This does not affect your right to make a complaint. Straits will retain your personal data as long as it is needed for the purposes outlined in Section 3, including but not limited to retaining personal data after account closures as required by applicable law and regulations.

Security
We have put in place appropriate security measures to protect your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We have a procedure to deal with any suspected personal data breach and will notify you, and other regulators, where we are legally required to do so.

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