Your Privacy is Our Priority

Ironbeam, Inc. (“Ironbeam”) is committed to safeguarding the personal information that you provide us. This privacy policy describes how we handle and protect personal information we collect about individuals, such as you, who apply for or receive our products and services. The provisions of this notice apply to former customers as well as our current customers. In order to preserve the integrity of the information you provide to us while opening an account with Ironbeam, one of its affiliates, or Introducing Brokers who maintain relationships with us, we want you to clearly understand how we strive to protect your privacy.

How We Protect Personal Information

Ironbeam restricts access to your personal information to firm personnel who require access to your information in order to conduct our business, service your account, and help you to accomplish your financial objectives. Individuals with access to your personal information utilize this information in order to provide you with the services you are seeking. Ironbeam’s firm personnel are required to maintain and protect the confidentiality of your personal information and must follow our established procedures to ensure this. To protect your information, we maintain physical, electronic and procedural safeguards that comply with federal standards for guarding the information we collect about you. We do not rent or sell your name or personal information to anyone.

Why and How We Collect Personal Information

When you apply for or maintain an account with Ironbeam, we collect personal information about you for business purposes, such as evaluating your financial needs, processing your requests and transactions, informing you about products and services that may be of interest to you, and providing customer service. Ironbeam may collect the following types of non-public personal information from you:

• Information you provide to us on applications and other forms, such as your name, address, date of birth, social security number, occupation, financial profile, income, and information regarding your trading history;
• Information about your account balances and transactions with us and with our affiliates;
• Information we receive from consumer reporting agencies, such as your credit history and creditworthiness, and other entities not affiliated with Ironbeam; and
• Information you provide to us to verify you identity, such as a passport, or received from other entities not affiliated with Ironbeam.

Disclosure to Non-Affiliated Third Parties

Ironbeam may disclose the types of non-public information listed above to the following types of parties:

• Governmental agencies, other regulatory bodies and law enforcement officials;
• Financial service institutions (e.g. advisers, dealers, brokers, trust companies and banks) with whom we have joint marketing agreements, such as agreements to market financial services or products that we jointly offer, endorse or sponsor; and
• Companies under contract to perform services for us or on our behalf, such as vendors that prepare and mail statements and transaction confirmations or provide data processing, computer software maintenance and development, transaction processing, auditing and marketing services.

Further, Ironbeam may disclose personal information with other non-affiliated companies as permitted or required by applicable law, such as in a response to a subpoena or legal process or in order to complete a transaction which you initiated and authorized. These providers acting on our behalf are required to maintain the confidentiality of any customer information they may obtain in connection with their services. Except as described in this privacy policy, we will not use your personal information for any other purpose unless we describe how such information will be used at the time you disclose it to us or we obtain your permission to do so.

Accessing and Revisiting Your Personal Information

We endeavor to keep our customers files complete and accurate. We will give you reasonable access to the information we have about you. Most of this information is contained in account statements that you receive from us and applications that you submit to obtain our products and services. We encourage you to review this information and notify us if you believe any information should be corrected or updated. If you have a question or concern about your personal information or this privacy notice, please contact your Ironbeam representative or call 1-800-341-1941 if you would like to opt out of the disclosure of nonpublic personal information to nonaffiliated third parties.