Brill Securities

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Our Commitment to Your Privacy: Brill Securities Inc. (“Brill”) has a long-standing policy of protecting the confidentiality and security of information we collect about customers of Brill. We will not share nonpublic information about you (“Information”) with third parties outside of J.P. Morgan Clearing Corp. (“JPMCC”) our clearing agent, without your consent, except for the specific purposes described below. This notice describes the Information we may gather and the circumstances under which we may share it. We provide our privacy policy to clients when they open a new account. We also provide it to current clients on a yearly basis.

Why We Collect and How We Use Information: We limit the collection and use of Information to the minimum we require to deliver superior service to you. Such service includes maintaining your account with us, processing transactions requested by you and administrating your business.

How We Gather Information: We get most Information directly from you, when you apply for, access and use financial products and services offered by Brill and its business partners whether in person, by telephone or electronically. We may verify this information or get additional information from consumer reporting agencies or public sources. This Information may relate to your finances, employment, avocations or other personal characteristics as well as transactions and interactions with others or us.

How We Protect Information: Our employees are required to protect the confidentiality of Information and to comply with our established policies. They may access Information only when there is an appropriate reason to do so, such as to administer our products or services. We also maintain physical, electronic and procedural safeguards to protect Information that comply with all applicable laws. Employees who violate our Privacy Policy are subject to disciplinary process.

Disclosure of Information: We may disclose any Information to JPMCC our clearing agents when we believe it necessary for the conduct of our business, or where disclosure is required by law. For example, Information may be disclosed for audit, to attorneys or to law enforcement and regulatory agencies to help us prevent fraud. We do not disclose to third parties information that is personally identifiable to you as a client or former client, except as described in this policy.

Former Customers: Even if you are no longer a customer of Brill for which we provide services, our Privacy Policy will continue to apply to you.

To Whom This Policy Applies: This Privacy Policy applies to products or services provided by Brill offices in the United States, used primarily for personal, family or household purposes (not business purposes).

Access to and Correction of Information: If you desire to review any file we may maintain for your personal Information, please contact Brill Securities. If you notify us that any Information is incorrect we will review it. If we agree, we will correct our records. If we do not agree, you may submit a short statement of dispute, which we will include in future disclosures of the disputed Information. Information collected in connection with, or in anticipation of, any claim or legal proceeding will not be made available.

Further Information: We reserve the right to change this Privacy Policy. The examples contained within this Privacy Policy are illustrations and they are not intended to be exclusive. This notice complies with a recently enacted Federal law and new SEC regulations regarding privacy. You may have additional rights under other foreign or domestic laws that may apply to you.