Dear Client:
ADM Investor Services (“ADMIS”) and its affiliated introducing broker that introduced your account to ADMIS, (hereafter
jointly called the “Companies”) are committed to protecting the privacy, accuracy and reliability of any personal
information you choose to provide. The “Companies” are further committed to safeguarding such information from loss,
misuse, unauthorized access, disclosure and alteration. This privacy policy statement is provided to you on behalf of the
”Companies” and addresses the “Companies” data collection, use and disclosure practices. This privacy policy may change
from time to time and you will receive written notification of any such changes. If your account was introduced to ADMIS by
an independent introducing broker or another Futures Commission Merchant, this privacy policy applies only to how your
personal information is handled and protected by ADMIS, not how it is handled and protected by your independent
introducing broker or Futures Commission Merchant.
Personal Information Collected
The reason the “Companies” collect information is to create and foster ongoing customer relationships. In the normal
course of this process, the “Companies” obtain and retain non-public (personal) information about you which is transmitted
to us either directly by you or via your broker in order to open an account. This includes your name, address, tax
identification number, approximate age, investment experience and other identifiable information. In addition, the
“Companies” may obtain information about you through our affiliates, credit reporting services, regulatory information
providers and other similar entities. The “Companies” limit such information to such facts as are necessary to establish a
relationship with you as a customer and to offer accurate and superior service in the normal course of business as it relates
to your account carried at the “Companies”.
The “Companies” also obtain and retain non-public (personal) information about you resulting from transactions involving
your financial investments. This includes your account balances, funding and transaction history. In addition, the
“Companies” obtain and retain non-public (personal) information about you in connection with information obtained
through an information-collecting device from a web server, often referred to as a “cookie”.
Use of Personal Information
The “Companies” use your personal information for three general purposes:
• First, the “Companies” use the information to approve and activate an account for you and/or to make changes or
additions to information previously provided to us to open an account for you.
• Second the “Companies” may use it to give you online access to your account information and the “Companies”’
proprietary information in a secured environment.
• Third, the “Companies” use the information in the normal course of business to transmit account activity
statements and related documents to you relating to activity in your account with the “Companies”.
Disclosure of Personal Information
The “Companies” take very seriously their responsibilities to keep your personal information private. The “Companies” will
not disclose non-public personal information about our customers except as required and permitted by law and in the
following instances:
• In processing or servicing of products or services offered by the “Companies” that have been consented to,
requested or authorized by the customer.
• The “Companies” may share your personal information with affiliates and subsidiaries and/or unaffiliated third
parties only as is necessary to verify the accuracy of the information you have provided, to conduct identity,
background and credit history checks, to process or collect payments, to service your account, including the
provision of account opening and risk management services, for audit purposes and/or to ensure regulatory
compliance.
• The “Companies” may be required to disclose personal information by law or legal process for a variety of reasons,
including protecting and defending the rights or property of the “Companies” and periodically reporting trading
gains or losses as required by the Internal Revenue Service. The “Companies” may also be required to disclose
personal information to the regulatory bodies whose jurisdiction they are subject to.
Except under the circumstances described above, The “Companies” will not disclose any of your personal information to
unaffiliated third parties, unless specifically authorized by you in writing to do so. The confidentiality and conditions of this
agreement will continue to be maintained even when you cease to do business with the “Companies”.
How the “Companies” Protect Personal Information
The “Companies” take reasonable measures to protect your personal information from unauthorized access through the
use of physical security, and use and access policies for employees. The “Companies” safeguard customer information from
unauthorized access by their confidentiality policies and/or limiting the number of employees permitted to access such
information through personalized staff passwords, and by having in place a process for disciplinary action where
appropriate.
Additionally, customer, or account activity related information is protected on the “Companies” Web sites with a variety of
security measures such as change control procedures, passwords, and physical access controls. The “Companies” also
employ a variety of other mechanisms to protect a user’s data from being lost, misused, or altered inappropriately.
Although the “Companies” take these measures to safeguard against unauthorized use of a user’s data, the “Companies”
cannot control Internet transmissions and cannot provide assurances that personal information transmitted to the
“Companies” will never be compromised.
Information Sharing with Affiliates of the “Companies”
Although by law we are permitted to share information with our affiliates and subsidiaries related to our transactions and
experiences with you, it is the policy of the “Companies” not to do so without your authorization, except in the limited
circumstances referenced above. Accordingly, the “Companies” will not share any personal information either provided by
you or obtained from third parties, unless it is necessary to do so for the purposes described above or it is required by law
or regulation or unless we have your specific written authorization.
The “Companies” Web site may contain hyperlinks to third parties’ Web sites. This privacy policy does not apply to those
third party Web sites. The “Companies” are not responsible for the privacy policies or content of any other Web site its
customers visit or link to, nor do the “Companies” have control over the use or security of any information provided to its
customers or collected by those Web sites. It is recommended that you become familiar with the privacy policies of those
Web sites that you visit or link to.
Accuracy of Personal Information
On an ongoing basis the “Companies” evaluate their efforts to protect your personal information and ensure its accuracy.
Should you identify any inaccuracy in the personal information included in any communication you receive from the
“Companies”, please notify your broker or the ADMIS Compliance Department immediately at 1-800-243-2649. The
“Companies” will take reasonable steps to ensure it is corrected on a timely basis.