Privacy Notice

Information We Collect

In connection with providing brokerage and related financial services, Great Point may collect nonpublic personal information about customers from sources including:

• Account applications and other forms;
• Transactions conducted with us, our clearing firms, or other financial institutions;
• Written, electronic, and verbal communications;
• Consumer reporting agencies, where applicable; and
• Other information necessary to provide services and comply with legal and regulatory obligations.

Information We May Disclose

Great Point does not sell customer information to third parties.

We may disclose nonpublic personal information as permitted by law, including:

• To clearing firms, custodians, transfer agents, and other service providers necessary to establish, maintain, service, or process customer accounts;
• To regulators, self-regulatory organizations, law enforcement agencies, and governmental authorities as required by law or regulation;
• To respond to subpoenas, court orders, or other legal processes;
• To protect against fraud, unauthorized transactions, claims, or other liabilities; and
• At the direction of, or with the consent of, the customer.

Protection of Customer Information

Great Point maintains physical, electronic, and procedural safeguards designed to protect customer information and comply with applicable federal standards.

Access to customer information is limited to employees and authorized service providers who require such information to perform their duties. Employees who improperly use or disclose customer information may be subject to disciplinary action.

Former Customers

We apply the same privacy protections to former customers as we do to current customers.

State Privacy Rights

Certain states may provide additional privacy rights. Great Point will comply with all applicable state privacy laws, including those relating to California residents.

Changes to this Privacy Notice

Great Point reserves the right to modify this Privacy Notice at any time. If material changes are made, customers will be provided with an updated notice as required by applicable law.