Privacy - Stonegate

STONEGATE CAPITAL MARKETS PRIVACY POLICY – REGULATION S-P (Revised November, 2018)

The following is the substance of the notice that will be used by the Firm until further notice:

When you use Stonegate Capital Markets as your broker-dealer, you entrust us not only with your hard-earned assets but also with your personal and financial data. We consider your data to be private and confidential, and we hold ourselves to the highest standards of trust in their safekeeping and use.

Privacy Notice

We collect nonpublic personal information about Stonegate Capital Market’s clients such as you from the following sources:

1. Information we receive from you on applications or other forms.

2. Information about your transactions with us, our clearing firm, or others.

Federal law has established guidelines requiring advance notice of disclosing your non-public information to third-parties and giving you the opportunity to “opt-out”. We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law, so in effect our customers are automatically “opted out”. Moreover, we will never release information about our customers or former customers unless one of the following conditions is met:

1. We receive your prior written consent.

2. We believe the recipient to be you or your authorized representative.

3. We are required by law to release information to the recipient.

We only use information about you and your account to help us better serve your investment needs or to suggest services or educational materials that may be of interest to you.

Confidentiality and Security

We have the responsibility to protect all information about your public and non-public, personal and private financial information. Our safeguards include, but are not limited to, the following:

1. All customer information is maintained in a security-controlled area located in the main office and supervised by the Principals of Stonegate.

2. Only authorized fingerprinted personnel may receive or collect and distribute incoming mail.

3. When outside (third-party) vendors perform a service on our behalf (e.g. accountants, consultants, banks, legal council), we will receive a signed confidentiality agreement prior to those services being provided.

4. Registered Representatives and Employees are instructed to provide locked, secure storage of all client information at all times.

5. We will provide secure removal of trash or unusable documents by shredding or some other secure manner of disposal.

6. Customer information will not be exchanged with other employees for any purpose, except on a “need-to-know” basis.

7. Electronic access to customer information is password protected.

Although the Firm does not ordinarily obtain consumer reports (credit reports) on its clients, the Firm shall treat consumer reports with the same degree of confidentiality as the other non-public personal information it obtains.

Protection of Customer Records

Firm personnel will be instructed to exercise care to avoid placing documents containing confidential information in areas where they may be read by unauthorized persons and store such documents in secure locations (e.g. locked drawers, file cabinets, offices) when they are not in use.

Firm personnel are prohibited from discussing confidential information in public places such as elevators, hallways, restrooms, or at social gatherings.

Furthermore, we will continue to adhere to the privacy policies and practices described in this notice even after your account is closed or becomes inactive.