US Privacy Statement

Last Updated: June 29, 2020

Customer Privacy Notice

BTIG, LLC understands your privacy is important and the firm has always been committed to maintaining your confidentiality. This notice will help you understand what types of personally identifiable information we may collect, how we use it, and how we protect your privacy. We recognize that you expect your personal information to be handled in a professional, confidential manner and we have adopted policies to safeguard your privacy. This statement explains the circumstances under which we may collect, maintain and use any personally identifiable information that you provide us.

Information We Collect

We collect information about you to help us provide services to you, offer new products or services, and fulfill legal and/or regulatory requirements. The types of information we collect may include:

• Information you provide through our sites or as part of the new account opening process. This includes information we receive from you on account opening applications or other forms, for example, your name, email, personal or business street address, social security number, assets and income. This also includes information you post or publish through our sites including, for example, customer organization details and customer employee contact information. We use this information in order to open your account, for AML checks, to provide you with services, for our research purposes and in connection with our general sales practices to notify you of opportunities.You may also apply for employment with us through our site. In that case, we may collect and process additional information for the purposes of considering your application for employment. In connection with an application for employment, your personal information will, in addition to the terms of this policy, be subject to the terms of an additional policy you are provided in connection with the submission of your application.
• Information about your transactions with us or others. This includes your transaction history, account balance, payment history, and parties to transactions. We use this information to provide you with the requested service to complete the transaction, to comply with our legal responsibilities and to manage the interactions between BTIG and you.

• Information you provide regarding marketing data preferences. We use this information in connection with our client support and to improve our offering of services to you.

• Information that we may receive from a consumer reporting agency. This includes information such as your credit worthiness and credit history. We use this information in connection with providing you with credit information and extending credit to you. Where you have applied for a job, we use a third-party service provider that captures contact and other publicly available data from the online application form and from other uploaded documents.

• Information we collect automatically through our sites. When you visit our sites, we automatically collect certain information such as the name of your Internet service provider, the public IP address of the computer or device you are using, the device ID, browsing history, the type of browser software and operating system that you use, the date and time you access this site, the Internet address, if any, from which you linked directly to this site, the Internet address, if any, to which you travel from this site and other similar traffic-related information.This information is mandatory, and we may use the foregoing information internally to help us improve our sites and the services that we provide through them, and we may provide such information to our employees, contractors, agents and designees to the extent necessary to enable them to perform certain site-related services (e.g., web hosting or maintenance services) on the firm’s behalf.

• Cookies. We use cookies and other tracking technologies to collect information about you as you navigate through our sites. Cookies and tracking technologies help us to make interactions with our sites easier and faster for you. We also use cookies and other tracking technologies to analyze trends, administer and improve the services provided through our sites and track activity and interactions with our sites. Other cookies we use are required to secure your connection by checking your identity and securing your access to your account.You can control the use of cookies at the individual browser level. If you reject or delete cookies, you can still use our sites, but your ability to use some features or areas may be limited. Please note that some features and tools on our sites may also be impaired if you block all cookies.

• “Do Not Track” technologies.We currently do not respond to web browser “Do Not Track” signals.

Information Sharing and Disclosure

We share personal information about you with third parties in certain circumstances.

• Where necessary to complete a transaction on your behalf.
• Where necessary to protect you against fraud, comply with a subpoena or other court or regulatory order or as otherwise required or permitted by law.
• Where a third party is providing services or support to us and in such capacity has agreed to maintain the confidentiality of the information it receives in providing those services and has also agreed that it is prohibited from using any information obtained for their own purposes outside of providing services to us.

We use Google Analytics for the purpose of tracking site traffic statistics. The data we share to obtain these statistics is abbreviated and/or anonymized such that your personal information is not shared.

We do not sell your personal information to anyone. In the event of a company level transaction or similar event, including, but not limited to, a combination, merger or buyout, we may transfer your information to such combined, new or successor entity.

Information Protection

We limit access to your personal and account information to those employees who have a need to know that information in order for us to provide products, services, support or assistance to you and who have been trained on the proper handling of personal information. We also maintain physical, electronic, and procedural safeguards to protect and guard your nonpublic personal information. If you decide to close your account(s) or become an inactive customer, we will continue to adhere to the privacy policies and practices as described in this or subsequent notices.

Data Security

We take reasonable and appropriate security measures to protect unauthorized access, alteration, misuse, or destruction of data located on and collected by our website. We maintain written supervisory procedures, controls and compliance policies designed to conform to or exceed legal requirements. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. If you have any questions about our security practices, you can contact us at [email protected], (833) 248-2375 and/or the address listed below.

Your Privacy Rights
Depending on where you are located, you may have the following rights in connection with information we collect about you:

• The right to lodge a complaint with a supervisory authority if our data collection practices do not comply with the laws and regulations;
• The right to access the information we collect about you (we may charge a reasonable, administrative fee, if further copies of information are requested);
• The right to correct inaccuracies in information we collect about you;
• The right to object to specific types of processing;
• The right to have information we collect about you “erased” or restrict processing of such information (but note that if you request that your information be “erased,” we may retain the information if necessary for a legitimate business purpose); or
• The right to withdraw consent for future processing of your information.

If you wish to exercise any of these rights, email us at [email protected], and we will respond to your request in a reasonable time. Depending on your location, you may have the right to file a complaint with a government regulator if you are not satisfied with our response.

Data Retention

We store your information as long as it is necessary to provide our services and fulfill our legal obligations.

Third Party Sites and Services

Certain third-party services or websites you use or navigate to from our site (such as social media sites) may have separate user terms and privacy policies that are independent from this Privacy Policy. We are not responsible for the privacy practices of these third-party services or applications. We recommend carefully reviewing the user terms and privacy statement of each third-party service, website and/or application prior to using it.

Children’s Privacy

Our services are intended for a general audience and are not directed to children. We do not knowingly collect personal information online from anyone under the age of 18, including children under the age of 13. If you believe that a child under the age of 13 may have provided us with personal information, please contact us at [email protected], and we will promptly delete that information from our records.

Changes to this Privacy Policy

This Privacy Policy was last updated on the date provided at the top of the page. Please note that we review and modify our Privacy Policy and other policies from time to time, and that these policies, and our collection and use of your information, are therefore subject to change. Your continued use of the website following the posting of a revised Privacy Policy means that you accept and agree to the changes. You will receive appropriate notice of changes to our Privacy Policy, and you are responsible for periodically visiting this page to check for any changes or updates.

Verification Process

We will contact you to confirm receipt of your request. We may also contact you to request additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests, we may request further information from you in order to verify your identity or right to receive the information requested, including through a third-party verification service. You may designate an authorized agent to make a request under the CCPA on your behalf, provided certain additional requirements are satisfied, and we may verify such authorized person’s identity using the procedures above.

Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request, but in certain cases, additional time might be required.

Contact Us

To contact us regarding this Privacy Policy and/or our privacy practices, you may contact us by using any of the following

• Email at [email protected]
• By phone at (833) 248-2375
• By mail at:
  Compliance Department
  BTIG, LLC
  600 Montgomery Street, 6^th Floor
  San Francisco, CA 94111