Multi-Bank Securities, Inc. Client Privacy Policy

This privacy policy discloses the privacy practices of Multi-Bank Services, Inc. for the website at www.mbssecurities.com (the ‘site’). This privacy policy does not cover information we collect by means other than the site. If you have any questions about the uses we make of information collected by means other than the site, you should inquire at or before the time you give such information to us. Multi-Bank Securities, Inc. has a policy of protecting the confidentiality and security of information we collect about our clients. We do not share nonpublic personal information about you outside of our organization without your consent except for the specific purposes described below, and in accordance with all applicable laws. This privacy policy describes the information we may gather and the circumstances under which we may share it.

Why We Collect, and How We Use, Information

We limit the collection and use of information to the minimum necessary to deliver superior service to you. Such service includes advising you about our products, services and other opportunities, maintaining your accounts with us, processing transactions requested by you or other persons authorized by you, and administering our business.

How We Gather Information and What Information We Gather

We gather most information directly from you when you apply for, access, and use our financial products and services – whether in person, by telephone or electronically. We may verify this information or gather additional information from consumer reporting agencies or other public or private sources. This information may relate to your finances, employment, avocations or other personal characteristics, as well as transactions and interactions with or through us or with others.

How We Protect Information

We require our employees, registered representatives, and investment advisor representatives to protect the confidentiality of information and to comply with our established policies. They may access information only when there is an appropriate reason to do so, such as to administer or offer our products or services. We also maintain physical, electronic and procedural safeguards to protect information that comply with all applicable laws. These include keeping computer terminals and servers in restricted areas, locking or otherwise limiting access to physical locations where we store nonpublic personal information, using password protection on servers and workstations, and using industry-standard encryption for all electronic transmissions of nonpublic personal information, whether Secure Sockets Layer (SSL) or otherwise. We require our service providers to comply with these same rules, where applicable. Employees who violate their obligations under this privacy policy are subject to a disciplinary process. Note that we cannot guarantee that information passing between us and you will remain secure while it is transmitted across the Internet.

Disclosure of Information

We may disclose any nonpublic personal information when we believe it necessary for the conduct of our business, or where disclosure is required by law. For example, we may disclose nonpublic personal information for audit or research purposes, to attorneys or other professionals, or to law enforcement and regulatory agencies to help us prevent fraud. In addition, we may disclose information to third party service providers (i) to enable them to provide business services for us, such as performing computer-related maintenance or processing services for us, (ii) to facilitate the processing of transactions requested by you, (iii) to assist us in offering other company products and services to you, or (iv) for credit review or reporting purposes. Without your consent, except as otherwise stated in this privacy policy, we will not disclose your nonpublic personal information to nonaffiliated third parties, such as those who may want to sell their products or services to you. For example, we do not sell customer lists and we will not sell your name to a catalogue company or telemarketer.

Access to, and Correction of, Information

Upon your written request, we will make available for your review any file we may maintain of your nonpublic personal information; provided, however, that we will not make available any information collected in connection with, or in anticipation of, any claim or legal proceeding. If you notify us that any of your nonpublic personal information is incorrect, we will review it. If we agree, we will correct our records. If we do not agree, you may submit a short statement of dispute, which we will include in any future disclosure of the disputed information.

Further Information

We reserve the right to change this privacy policy at any time and such changes will become effective immediately upon posting on our website at www.mbssecurities.com and/or www.eConnectDirect.com. The examples contained within this privacy policy are illustrations and are not intended to be exclusive.