Dear Client:
ADM Investor Services (“ADMIS”) and its affiliated introducing broker that introduced your account
to ADMIS, (hereafter jointly called the “Companies”) are committed to protecting the privacy,
accuracy and reliability of any personal information you choose to provide. The “Companies” are
further committed to safeguarding such information from loss, misuse, unauthorized access,
disclosure and alteration. This privacy policy statement is provided to you on behalf of the
”Companies” and addresses the “Companies” data collection, use and disclosure practices. This
privacy policy may change from time to time and you will receive written notification of any such
changes. If your account was introduced to ADMIS by an independent introducing broker or another
Futures Commission Merchant, this privacy policy applies only to how your personal information is
handled and protected by ADMIS, not how it is handled and protected by your independent
introducing broker or Futures Commission Merchant.
Personal Information Collected
The reason the “Companies” collect information is to create and foster ongoing customer
relationships. In the normal course of this process, the “Companies” obtain and retain non-public
(personal) information about you which is transmitted to us either directly by you or via your broker
in order to open an account. This includes your name, address, tax identification number,
approximate age, investment experience and other identifiable information. In addition, the
“Companies” may obtain information about you through our affiliates, credit reporting services,
regulatory information providers and other similar entities. The “Companies” limit such information
to such facts as are necessary to establish a relationship with you as a customer and to offer
accurate and superior service in the normal course of business as it relates to your account carried at
the “Companies”.
The “Companies” also obtain and retain non-public (personal) information about you resulting from
transactions involving your financial investments. This includes your account balances, funding and
transaction history. In addition, the “Companies” obtain and retain non-public (personal)
information about you in connection with information obtained through an information-collecting
device from a web server, often referred to as a “cookie”.
Use of Personal Information
The “Companies” use your personal information for three general purposes:
• First, the “Companies” use the information to approve and activate an account for you
and/or to make changes or additions to information previously provided to us to open an
account for you.
• Second the “Companies” may use it to give you online access to your account information
and the “Companies”’ proprietary information in a secured environment.
• Third, the “Companies” use the information in the normal course of business to transmit
account activity statements and related documents to you relating to activity in your
account with the “Companies”.
Disclosure of Personal Information
The “Companies” take very seriously their responsibilities to keep your personal information private.
The “Companies” will not disclose non-public personal information about our customers except as
required and permitted by law and in the following instances:
• In processing or servicing of products or services offered by the “Companies” that have
been consented to, requested or authorized by the customer.
Disclosure of Personal Information (continued)
• The “Companies” may share your personal information with affiliates and subsidiaries
and/or unaffiliated third parties only as is necessary to verify the accuracy of the
information you have provided, to conduct identity, background and credit history checks,
to process or collect payments, to service your account, including the provision of account
opening and risk management services, for audit purposes and/or to ensure regulatory
compliance.
• The “Companies” may be required to disclose personal information by law or legal process
for a variety of reasons, including protecting and defending the rights or property of the
“Companies” and periodically reporting trading gains or losses as required by the Internal
Revenue Service. The “Companies” may also be required to disclose personal information to
the regulatory bodies whose jurisdiction they are subject to.
• Except under the circumstances described above, The “Companies” will not disclose any of
your personal information to unaffiliated third parties, unless specifically authorized by you
in writing to do so. The confidentiality and conditions of this agreement will continue to be
maintained even when you cease to do business with the “Companies”.
How the “Companies” Protect Personal Information
The “Companies” take reasonable measures to protect your personal information from unauthorized
access through the use of physical security, and use and access policies for employees. The
“Companies” safeguard customer information from unauthorized access by their confidentiality
policies and/or limiting the number of employees permitted to access such information through
personalized staff passwords, and by having in place a process for disciplinary action where
appropriate.
Additionally, customer, or account activity related information is protected on the “Companies” Web
sites with a variety of security measures such as change control procedures, passwords, and physical
access controls. The “Companies” also employ a variety of other mechanisms to protect a user’s data
from being lost, misused, or altered inappropriately.
Although the “Companies” take these measures to safeguard against unauthorized use of a user’s
data, the “Companies” cannot control Internet transmissions and cannot provide assurances that
personal information transmitted to the “Companies” will never be compromised.
Information Sharing with Affiliates of the “Companies”
Although by law we are permitted to share information with our affiliates and subsidiaries related to
our transactions and experiences with you, it is the policy of the “Companies” not to do so without
your authorization, except in the limited circumstances referenced above. Accordingly, the
“Companies” will not share any personal information either provided by you or obtained from third
parties, unless it is necessary to do so for the purposes described above or it is required by law or
regulation or unless we have your specific written authorization.
The “Companies” Web site may contain hyperlinks to third parties’ Web sites. This privacy policy
does not apply to those third party Web sites. The “Companies” are not responsible for the privacy
policies or content of any other Web site its customers visit or link to, nor do the “Companies” have
control over the use or security of any information provided to its customers or collected by those
Web sites. It is recommended that you become familiar with the privacy policies of those Web sites
that you visit or link to.
Accuracy of Personal Information
On an ongoing basis the “Companies” evaluate their efforts to protect your personal information
and ensure its accuracy. Should you identify any inaccuracy in the personal information included in
any communication you receive from the “Companies”, please notify your broker or the ADMIS
Compliance Department immediately at 1-800-243-2649. The “Companies” will take reasonable
steps to ensure it is corrected on a timely basis.