This Privacy Policy ("Policy") covers the following affiliated companies in the Lumentrades family of companies: Lumentrades Financial Corporation, Lumentrades Securities LLC, Lumentrades Futures LLC, Lumentrades Capital Management, LLC, Lumentrades Insurance Services, Inc., Lumentrades Financial Corporate Services, Inc., Lumentrades Savings Bank, and Lumentrades Securities (Australia) Limited (including its United Kingdom branch office). These entities are collectively referred to as "affiliated companies," "we," "us," and "our" throughout this Policy.

We are committed to maintaining the privacy and confidentiality of our customers' personal information. In the course of offering and providing financial products and services, we collect and maintain certain personal information. This Policy explains what personal information we collect and how we use and share such personal information. It also explains what you can do to limit the use and sharing of your personal information.

We do not disclose personal information about our customers to non-affiliated third parties, except as described below.

When you apply for a financial product or service, open or maintain an account with us, or when you agree to allow us to provide personalized advisory services, we may collect the following types of information:

• Information you provide online and on applications or other forms, or through discussions we have with you or your representatives, such as your name, address, social security number, date of birth, income, employment information, investment experience, risk tolerance, and information about your personal investment goals or objectives
• Information about your transactions with or through us, such as your account balance, trading activity, loan amount, and account history, if applicable
• Information about you from consumer reporting agencies and other third parties, such as your credit score
• Information you provide us about your external financial accounts in order for us to provide you with special product and service features
• Technical, navigational and other information transferred when visiting our websites or using our mobile applications, such as IP address, device type, and browser type

In addition, we may compile aggregate, anonymous, or de-identified data from various sources, including but not limited to accounts and transactions. This data, which we may use for our business purposes consistent with applicable law, does not identify individual customers.

We may disclose personal information we collect, such as the categories described above, to make our financial products and services, as well as those offered by our service providers, available to you. We may also use and disclose personal information with your consent. If you decide to withhold certain information, it may limit our ability to provide you with the services or products you requested or that may be of interest to you. We do not disclose personal information about former customers to anyone outside of our affiliated companies except as permitted or required by law; to cooperate with regulators and law enforcement authorities; and to current or former corporate customers of Lumentrades Financial Corporate Services, Inc. to provide reporting and other services consistent with the terms of an employee stock plan.

We may disclose your personal information to the following entities:

• Our affiliated companies (please see below to learn how you may limit the sharing of some of this information for marketing purposes by our affiliated companies)
• Non-affiliated third parties that perform services, such as marketing or market research, on our behalf (for example, we may provide your name, address, phone number, or e-mail address to third parties that send e-mail or regular mail on our behalf)
• Non-affiliated third parties that service, maintain, or process your transactions and accounts (for example, companies that provide administrative, telecommunications, computer, trade execution, payment, and securities clearing services, and that prepare and mail account statements and transaction confirmations and other services in connection with the operation of our business)
• Non-affiliated third parties as permitted or required by law, or to cooperate with government agencies or regulators, (including for tax purposes), securities exchanges, self-regulatory bodies (such as FINRA and NFA) and law enforcement officials (for example, for reporting suspicious activity or transactions)
• Non-affiliated third parties in order to protect against actual or potential fraud or unauthorized transactions, and to protect the security of our records and systems, unless prohibited by law
• Non-affiliated third parties at your direction or for which you have provided your express consent (for example, banking or financial institutions and professional service providers)
• non-affiliated third parties in connection with Lumentrades Financial Corporate Services, Inc.’s provision of services to employee stock plan sponsors, but only in connection with activities associated with your Lumentrades Securities Stock Plan account
• Non-affiliated third parties in connection with the proposed or actual financing, insuring, sale, securitization, assignment, or other disposal of all or part of our business or assets (including accounts) for the purposes of evaluating and performing the proposed transaction.

We require that commercial entities (as described above) with which we share your personal information agree to keep your information confidential. We also prohibit those entities from using or disclosing your information except for a limited purpose and to the persons for whom disclosure was intended, or as otherwise permitted or required by law. Service providers to whom we disclose personal information must agree to contractual requirements consistent with our privacy and security policies. We prohibit our service providers from using personal information except for the specific purpose for which we provide to them, and we require them to comply with legal obligations applicable to the personal information at issue.

We may disclose information about your external financial accounts to our affiliated companies to provide you with account aggregation services and for marketing purposes unless you opt-out of such sharing.

We will request your consent before we use or disclose your personal information for a materially different purpose than those set forth in this Policy. Consent may be obtained by any legally sufficient method. For example, depending on the circumstances and applicable laws, consent may be obtained by providing you with notice and the opportunity to opt-out.

You may limit or "opt-out" of our sharing your personal information with non-affiliated third parties for their marketing purposes. However, because we do not currently share your personal information with any non-affiliated third party in a manner that would trigger this opt-out right, there is no need at this time for you to opt-out or take any other action telling us not to share such information with non-affiliated third parties.

You may also opt-out of our sharing certain personal information (for example, information other than your transactions and experiences with us, such as your credit report) among our affiliated companies. However, because we only share information about your transactions and experiences (for example, account balance, trading activity, loan amount, and account history) with our affiliated companies, there is no need at this time for you to exercise your opt-out right.

Finally, you may also limit certain kinds of marketing from our affiliated companies. You may elect to restrict our affiliated companies from marketing their products or services to you based on information about you that we share with them. Since our affiliated companies engage in such marketing from time to time, we are providing you with the ability to opt-out so that you do not receive these marketing communications in the future. To limit these marketing offers, please contact us by using the mail or telephone contact information provided below.

Your choice to limit marketing offers from our affiliated companies will apply until you tell us otherwise. You may change your opt-out status at any time. For consumers with joint accounts, an opt-out direction by one joint account holder will be treated as applying to all of the associated joint account holders.

The personal information that we collect from you will be stored in the United States and other countries that may have different privacy laws and standards than those in your country of residence. Your personal information may be transferred to or processed in the United States by us or by a third party service provider working for us. By submitting personal information via our website or other means, you agree to such storage, transfers and processing.

Our third party service providers may hold your personal information in countries other than your own, including the United States. You acknowledge and understand that the protection of your personal information will be subject to the applicable laws of each such jurisdiction, which may not provide for the same protection as your country of residence. For example, government entities in the United States and other countries may have certain rights to access your personal information. If you have questions about our policies and practices with respect to service providers outside your jurisdiction, including the collection, use, disclosure, or storage of personal information by our service providers worldwide, and you are entitled by applicable law to be provided this information, you may contact our Chief Privacy Officer by e-mail at CPO@Lumentrades.com. Please provide your first and last name and street address in your request.

We maintain reasonable physical, administrative, and technical safeguards to protect your personal information. Our employees and third party service providers have access to your personal information only on a "need to know" basis. We conduct regular internal audits of our business practices and procedures in order to protect your personal information.

In addition to our security measures, you can also take steps to maximize your security online and to protect your confidential information. Additional information on these topics can be found on our website at the Security Center link.

We and our third-party service providers may collect and store certain information when you visit or interact with our website (“Usage Information”). This Usage Information may be stored or accessed using tracking technologies such as “cookies” and “web beacons” that may be downloaded to your personal computer, tablet, mobile phone or other device (“Device”) when you visit or interact with our website. Usage Information may include but is not limited to:

• IP address, UDID or other unique device identifier, a number that is automatically assigned to your Device and used by us to identify your Device;
• Device functionality and characteristics (including browser, operating system, hardware, and mobile network information);
• The URL that referred you to our website;
• The areas within our website that you visit and your activities, including remembering your preferences
• Device location.

"Cookies" are small amounts of data that a website can send to your web browser and store on your computer. Cookies do not contain personal information (unless you knowingly provide it). We use both HTML cookies and Local Shared Objects (sometimes referred to as Flash cookies) that are built for use with the Adobe® Flash® Player for authentication purposes and to enhance navigation and website functionality. If you access your account online, cookies may be used to verify your identity, to authenticate you as a user on our system and to personalize aspects of your experience on our website. We also use cookies to let us know how our customers and other visitors are using our website so that we can optimize their experience. We permit certain third party advertising providers to set cookies and use related technology such as web beacons or “clear GIFs” through our website and other websites on which we advertise, and via HTML email messages, to track performance of advertisements and to collect aggregate data on web page viewing.

Most web browsers can be set to notify you when an HTML cookie is placed on your computer. You can manually delete HTML cookies and set most browsers to refuse to accept HTML cookies, although doing so may affect your website experience. Flash cookies may be removed by managing your Adobe® Flash® Player settings. To delete or prevent placement of Flash cookies, you will need to visit the Adobe® Flash® Player Help site at www.adobe.com/go/settingsmanager, click on the hyperlink for "Website Privacy Settings Panel" on the left side of the screen, and follow the instructions for preventing third party Flash content from storing data on your computer.

Additional information about tracking technologies can be found on our website. Visit the Security Center link on our website and select Information about Tracking Technologies.

Interest-based advertising

We use "interest-based" ads, which are also known as "online behavioral advertising." We may partner with ad networks and other advertising providers (“Advertising Providers”) who serve ads on behalf of us and others on non-affiliated sites. Some of these third parties may use cookies and other technologies to collect information about your online activities over time and across third party websites or online services to deliver advertising based on your interests and preferences, as inferred from your browsing history. Some of these ads may be personalized, meaning that they are intended to be relevant to you based on information that Lumentrades and its Advertising Providers collect about your visits to this site and elsewhere over time.

Do Not Track

Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third party web sites or online services (for example, browser “do not track” signals). Because a “Do Not Track” protocol has not been finalized, the information collection and disclosure practices of our website, and the choices that our website provides to consumers, will continue to operate as described in this Policy, whether or not a Do Not Track signal is received. Currently, we do not monitor or take any action with respect to these signals or other similar mechanisms.

As a customer, you may access and update some of your personal information. You may log on to our website using your user name and password and, from the home page, click on My Profile just under the Accounts tab and select the information you want to change.

We make reasonable efforts to maintain your personal information in an accurate, complete and up-to-date form. Please contact us if you believe that your personal information is inaccurate, incomplete, or out-of-date. Or, where entitled by applicable law, you may request access to your personal information by sending an e-mail to CPO@Lumentrades.com. Please include your first and last name and street address in your request. You may also update your information by calling or writing us using the contact information provided below. We will process your request in compliance with local laws and our policies and procedures. Please note that before we are able to provide you with any information or correct any inaccuracies, we may ask you for additional information to verify your identity.

Under certain circumstances, we may be unable to provide access to all of your personal information. We may deny or restrict access or deny your request to change your personal information for legally permissible reasons, such as where the information contains references to other individuals and is not reasonably severable; where it cannot be disclosed for legal, security, or commercial proprietary reasons; or where we have your personal information in our capacity as a third party administrative record keeper. We will advise you of any reason for denying or restricting an access request to the extent permitted by law, rule, or regulation.

We may update this Policy from time to time, and will review it at least annually. We encourage you to periodically check back to this Policy to learn about updates to our privacy practices.

California law requires that we obtain your affirmative consent before we share your non-public personal information with non-affiliated third parties for their own marketing purposes. However, because we do not currently share personal information about you with any non-affiliated third party in a manner that would trigger this requirement, there is no need at this time for us to seek your consent.

If you wish to opt-out of our sharing your personal information with our affiliated companies for marketing purposes, please contact us by telephone or mail:

Lumentrades Financial Corporation
P.O. Box 484
Jersey City, NJ 07303-0484

From within the U.S.: ()
From outside the U.S.:

For questions regarding our Privacy Statement, please visit the Contact Us page on our website or call
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