PROTECTING YOUR PRIVACY
OUR PLEDGE TO YOU
While information plays a large role in our ability to provide superior service, we know that our most important asset is our customers’ confidence in us. Keeping customer information secure, and using it only as our customers would want us to, are matters of principle for all of us at SpiderRock. With this in mind, here is our pledge to each and every SpiderRock customer.
- Respect the trust you place in us and the confidential nature of the information you provide through your financial relationship with us.
- Limit the collection and use of customer information to what we believe would be useful to service your accounts, administer our business, or tell you about our services.
- Restrict employee access to customer information to those who need to know in order to provide services to you.
- Educate our employees to reinforce the importance of confidentiality and customer privacy.
- Maintain appropriate security standards and procedures to protect information about you.
- Respond quickly to your request to correct inaccurate information.
- You can count on us to protect the privacy of the information you have entrusted to us and to provide you with the responsive, professional service you deserve.
INFORMATION WE COLLECT
The information we collect and maintain about you comes primarily from you during the course of your doing business with SpiderRock. This personal information, not available publicly, comes from the following sources:
- Information you provide to us when you fill out account opening documents, complete a form, or make a request for services. This includes your name, address, e-mail address, age, Driver’s License number, Social Security Number, investment objectives, investment experience, telephone number(s), occupation, assets and income.
- Information from your transactions with us, such as your account balance, account usage and margin loan history.
- Information obtained from others, such as credit reporting agencies.
- If any of the above noted personal information changes, please contact us so that we may update your account.
HOW INFORMATION HELPS BOTH YOU AND US
Our mission is clear: to help you reach your trading goals. Information about you and your accounts plays a key role in our ability to succeed in this mission. It also helps us service your accounts and administer our business.
- For example, we use information about you to:
- Respond more accurately and efficiently to your requests.
- Identify opportunities to give you more convenience and control by developing new services that may benefit you.
- Secure your accounts and help protect you and SpiderRock from fraud.
KEEPING INFORMATION SAFE
We limit access to the information we have about you to those employees who need to know to provide you with services to help you meet your financial needs. We maintain appropriate physical, electronic and procedural safeguards to protect your information.
THE IMPORTANCE OF BEING ACCURATE
We have security standards and procedures in place designed to prevent unauthorized access to your accounts and personal information. A key part of this process ensures that all information we have about you is accurate and up-to-date. If you ever discover inaccuracies in our data or if your personal information changes, we urge you to notify us immediately.
PROTECT YOUR PASSWORD
One way to guard against unauthorized access or intrusion to your account is to keep your SpiderRock password private. Note: SpiderRock does not have access to your password. Here are some suggestions on how to choose and safeguard your password:
- Do not share your password with anyone.
- Do not write your password down.
- Type your password each time it is required of you. Do not save your password on the site entry screen or develop a shortcut to reproducing your password.
- Avoid using easily guessed words such as your name, user id, or any variation thereof (backwards, changing case, etc.).
- Avoid words referring to anything noticeable about you: the name of your spouse, child, pet, your favorite football team, or literary character.
- Avoid any combination of your office number, address, birthday, or anniversary.
- Avoid any combination of your license-plate number, your social-security number. If you feel that your password is no longer secure, please change it immediately.
To protect your privacy, we limit the information we share outside SpiderRock. We conduct our business with great respect for the confidential nature of the information being provided. We will not share information about you except as outlined below. We do not sell customer (current or former) information to third parties under any circumstance.
SHARING INFORMATION WITH COMPANIES WHO HELP US PROVIDE YOU SERVICES
We may share the information described under the Section captioned “Information We Collect” with affiliates of SpiderRock. Additionally, this information may be shared with companies external to SpiderRock (“outside companies” or “third parties”) to complete a transaction you have requested, to help us service your account, and to allow us to offer you improved products and services. We are highly selective in choosing these companies. All companies with whom we do business are contractually obligated to comply with strict standards regarding security and confidentiality, and the information can be used only for the sole purpose of providing the service we have requested the company to perform.
SHARING INFORMATION WITH COMPANIES WHO HELP US PROVIDE YOU SERVICES (CON’T)
Examples of the types of outside companies with which we may share information to help us service your account include non-financial companies that perform services for us such as data processing and companies that perform securities execution and clearing services on our behalf. In order to offer improved products and services to you, we may engage outside companies who use third-party technology to assist us with certain functions such as client satisfaction surveys, business or marketing analysis, or other data collection activities relevant to our business. Use of any information shared is strictly limited to the performance of the task we request and for no other purpose.
SHARING INFORMATION IN OTHER SITUATIONS
SpiderRock may also be required to release your information to third parties as required by law or to cooperate with regulators or law enforcement authorities. This may include releasing such information to nonaffiliated parties such as the Financial Industry Regulatory Authority (FINRA), the Securities and Exchange Commission (SEC), or the Internal Revenue Service (IRS) as well as any of the securities exchanges or regulatory authorities in states in which SpiderRock is registered. SpiderRock may also be required to disclose nonpublic, personal information as required under court order or subpoena or for certain obligations of SpiderRock under the USA Patriot Act.
LINKING TO OTHER SITES
From time to time, SpiderRock Web Site may provide links to other Web Sites not owned or controlled by SpiderRock that we think might be useful or of interest to you. We cannot, however, be responsible for the privacy practices used by other Web Site owners or the content or accuracy of those other websites. Links to various non-SpiderRock Web Sites do not constitute or imply endorsement by SpiderRock of these websites, any products or services described on these sites, or of any other material contained in them. It is always your choice whether or not to participate in certain promotions and special offers that may be made to you via these other web sites.
If you no longer wish to receive marketing and promotional material from SpiderRock, you can opt out by clicking on the “unsubscribe” link on the e-mail you received from SpiderRock. Even if you decide to opt out and no longer receive SpiderRock marketing and promotional material, you are required to maintain an email address with SpiderRock so that we can continue to email you legally required notices and trade related information in order to transact business effectively and follow regulatory guidelines.
AN ONGOING COMMITMENT TO YOUR PRIVACY
We are just as committed to protecting the privacy of our former customers as we are our current customers. If you choose to close your account(s) or become an inactive customer, you will continue to be protected by the privacy policies and principles described in this policy.
SHARING OF NONPUBLIC PERSONAL INFORMATION
SpiderRock does not disclose nonpublic personal information relating to current or former customers to any third parties, except as required or permitted by law, including but not limited to any obligations of ours or our clearing firms’ under the USA PATRIOT Act, and in order to facilitate the clearing of customer transactions in the ordinary course of business.
PERSONAL INFORMATION COLLECTED
In order to service your account as clearing broker, information is provided to our clearing firms’ by SpiderRock. We collect information from you in order to provide the financial services that you have requested. The information SpiderRock collects and provides to our clearing firms may come from the following sources:
- Information received from you, such as your name, address, telephone number, social security number, occupation, and income.
- Information relating to your transactions, including account balances, positions, and activity.
- Information that may be received from consumer reporting agencies, such as credit bureau reports and other information relating to your creditworthiness.
- Information that may be received from other sources with your consent or with the consent of your introducing broker.
SpiderRock strives to ensure that their systems are secure and that they meet industry standards. We protect personal information that is provided to us by maintaining physical, electronic and procedural safeguards that either meet or exceed applicable law. Where appropriate, SpiderRock employs firewalls, encryption technology, user authentication systems (i.e. passwords and personal identification numbers) and access control mechanisms to control access to systems and data. Third parties who may have access to such personal information must also agree to follow appropriate standards of security and confidentiality. SpiderRock instructs their employees to use strict standards of care in handling the personal financial information of customers. As a general policy SpiderRock’s staff will not discuss or disclose information regarding an account except with authorized personnel of that account or as required by law or pursuant to regulatory request and/or authority.
Effective December 01, 2015