Privacy Policy

Water Street Solutions® is committed to protecting all nonpublic information it collects on our current and former customers. This notice describes how Water Street Solutions® protects all non‐public information received from our customers. Federal Law may require Water Street Solutions® to collect personal information in order to verify its customers’ identities when applying for an account.

Water Street Solutions® collects nonpublic personal information about the client from the following sources:

∙ Information we receive from a client on applications or other forms.

∙ Information we receive about a client’s transactions with us, our affiliates, or others.

Water Street Solutions® discloses client information to the carrying clearing firms for account opening purposes and for customer identity verification purposes. Client information is disclosed to no one else and kept private, except as permitted by law. Water Street Solutions® retains personal current and former customer information and discloses that information only as necessary to service our customers. Only under specific circumstances may Water Street Solutions® disclose the following kinds of nonpublic personal information about you:

∙ Name, date of birth, residential or business address, social security number, governmental photo ID, banking information, financial background, and investing experience.

∙ For non‐individual accounts (corporation, LLC, partnership, trust), Water Street Solutions® will also obtain documents that show the existence of an entity. These may include certified articles of incorporation, a partnership agreement, a government issued business license, or a trust instrument.

∙ For all non‐US persons, Water Street Solutions® will also obtain, at a minimum, a TIN, passport number and country of issuance, an alien identification card number, or the number and country of issuance of any other government issued document evidencing nationality or residence and bearing a photograph.

Water Street Solutions® may disclose personal information about current or former customers to third parties in the following possible circumstances:

∙ As required to process or service clients’ accounts or transactions.

∙ As required by regulators, tax authorities and examiners, law enforcement personnel or in response to a subpoena or legal process where information is required.

∙ As may be appropriate to protect against fraud or illegal activity, for the safety of the customers, employees, or property of Water Street Solutions®.

∙ As specifically directed by a customer of Water Street Solutions® to disclose on their behalf.

Water Street Solutions® restricts access to nonpublic information about our clients to anyone not employed by the company or by the third parties referred to above.We maintain physical, electronic, and procedural safeguards that comply with federal standards to safeguard your nonpublic personal information0.

Customers and counterparties must consent to the recording of all oral communications that are subject to recording Rules. The receipt of this Privacy Policy is your notice that all conversations between you and a registered associated person of Water Street Solutions® will be recorded and maintained on file under secure measures as outlined in this notice for a period of one year. Should you object to this recording policy, you will need to notify our office within 10 calendar days of your unwillingness to be subject to your conversations being recorded while speaking with a registered associated person of Water Street Solutions® . After this 10-calendar day period, your silence will be accepted as your consent to this policy.