At Boustead Securities, LLC (“Firm”), protecting your privacy is our top priority. When you work with a financial services firm, you may share non-public personal information which may be necessary to providing superior products and service. Therefore, we understand our obligation to keep information about you secure and confidential. We will inform you of our policies for collecting, using, securing, and sharing your non-public personal information (“Customer Information”) the first time we do business and every year that you remain a customer with us. The following information describes our policies and procedures for handling your personal financial information.

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Information We Collect. 

We collect and use various types of information we believe is necessary to administer our business, and to offer you the best possible customer service. Customer Information we collect is categorized into the following types: (1) information we receive from you on applications, or on other forms, through telephone or in-person interviews, such as your name address, phone number, social security number; your assets, income and other household information; (2) information about your transactions and account experience with us or others, such as your account balance, transaction history; (3) information from consumer reporting agencies, such as information regarding your creditworthiness or credit history; (4) other general information we obtain about you that is not assembled for the purpose of opening an account or offering certain products or services that you may request, such as demographic information.

 

Information We Share. 

We may disclose your non-public personal information as part of servicing and maintaining your policy, contract or account, and/or for other purposes as permitted or required by law. In the normal course of business, as described below:

• Service providers, contractors, and vendors, including to process transactions, maintain accounts, and provide information technology, marketing, and recruiting and human resources‑related services

• Third parties and non-affiliates, such as your financial professionals, representatives, other financial institutions, credit bureaus, product sponsors, and business contacts and partners related to the provision or offering of products or services, human resources, and business operations, management, and administration 

• Governmental authorities and other third parties, such as self-regulatory organizations, to comply with applicable laws and legal requirements or in response to court orders, subpoenas, government inquiries, other legal processes, to defend against claims and allegations, or to protect property, personnel, or members of the public

• Members of the public and our clients when permitted by law, for instance, items of interest pertaining to our business (e.g., photographs taken at our events)

• Other parties to which you direct us to disclose personal information, or to which we inform you we may disclose your data, or to which we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or to any person who is otherwise deemed to be our successor or transferee

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We will not disclose personal information about current or former customers to non-affiliated third parties, except as permitted or required by law, and we do not sell any personal information about you to any third party.

 

RIGHTS UNDER STATE LAW (CALIFORNIA)

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If you are a resident of California, you may have rights under the California Consumer Privacy Act of 2018 (“CCPA”) regarding your personal information, as described in this section.

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What is Covered by this Section of the Privacy Policy?

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Much of the personal information that our Firm collects is exempt from the rights provided by CCPA. The rights under the CCPA described below do not apply, for instance, to personal information collected, processed, sold or disclosed pursuant to the Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act. As a general matter, those laws apply to nonpublic personal information about individuals who obtain financial products or services primarily for personal, family, or household purposes. The CCPA also exempts from most of its provisions, including the privacy policy notification requirements, certain information processed in the business-to-business context (e.g., information about an individual acting in his or her capacity as a representative of a company) and information about employees, job applicants, and contractors when processed in that context. This section (6.B); therefore, does not cover information falling with the scope of these exemptions or to which the CCPA’s relevant provisions do not apply.

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Access and Deletion Rights Under the CCPA

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• Right to Request Disclosure of Personal Information We Collect and Share (Access Rights)

  • Individuals whose personal information is covered by the CCPA have a right to request that our Firm provide the following information:

    • The categories of personal information that our Firm has collected about you;

    • The categories of sources from which our Firm collected the personal information;

    • The business or commercial purposes for which our Firm collected and/or sold the personal information;

    • The categories of any third parties with which our Firm shared the Personal information; or

    • The specific pieces of personal information our Firm collected over the past year.

  • Such individuals may also submit a request for the following additional information:

    • The categories of personal information, if any, our Firm has sold about you, categories of third parties to which our Firm sold that personal information, and the categories of personal information sold to each type of third party;

    • The categories of personal information that we have disclosed for a business purpose; or

    • Our responses to any of these requests will cover the 12-month period preceding our receipt of the request.

• Right to Request the Deletion of Personal Information We Have Collected from You (“Deletion Rights”)

  • Individuals whose personal information is covered by the CCPA may also request that we delete personal information covered by the CCPA that we maintain. Upon receiving and appropriately verifying such a request, our Firm will delete the personal information, unless that information is necessary for our Firm to:  complete the transaction for which we collected the information; provide you with a good or service you requested; perform a contract our Firm entered into with you; detect security incidents; maintain the functionality or security of our firm’s systems; comply with or exercise rights provided by the law; or use the information internally in ways that are comparable with the context in which you provided the information to our Firm or that are reasonably aligned with expectations based on your relationship with our Firm, among other things. We may also retain information where another exception to the deletion requirements in Cal. Civ. Code § 1798.105(d) applies. Please note that if you request that your personal information be deleted, you may no longer be able to access or use certain parts of our or our affiliate’s websites.
     

• How to Exercise Access and Deletion Rights

  • To exercise these CCPA rights, please contact us at (949) 295-1580. You may also submit a request to our Firm in person through the representative that offered you our Firm’s services.

 

• Our Processes for Responding to CCPA Requests

  • Verifying requests:  Depending on the nature of your request, we may ask you for additional information to verify your request and identity and a declaration attesting to your identity, signed under penalty of perjury.

  • Timeline for responding:  We will respond to requests for access or deletion as soon as practicable and, in any event, generally within 45 days after receiving your request. We may extend this period to 90 days in some cases.

  • Using an agent:  You may designate an agent to submit a request on your behalf.

  • Requests for household information:  There may be some types of personal information that can be associated with a household. Requests for access or deletion of household personal information must be made by each member of the household.

  • Sales of Information:  We do not and will not sell personal information, nor have we sold any of the categories of personal information in the last 12 months.

  • Non-discrimination:  We are committed to complying with the law. If you exercise any of the rights explained in this policy, we will continue to treat you fairly.

  • Accessibility:  our Firm is committed to ensuring that our communications, such as our Sites, are accessible to individuals with disabilities. To submit accessibility‑related requests or report barriers to accessibility, please contact us at (949) 295-1580.

 

Minors’ Information

Our website and our services are not directed to minors under the age of 18, nor do we sell information about minors. If we learn that we have erroneously collected personal information of a child under 18, we will take steps to delete such information from our files as soon as possible.

 

Third-Party Links

Our website may contain links to third-party websites. Please be aware that we are not responsible for the privacy practices of other websites. We  offer no guarantees about the safety or suitability of websites featured on third-party links, and users who choose to follow such links do so at their own risk.

 

Protection and Confidentiality of Information. 

We have procedures in place that limit access to Customer Information to only those employees, representatives and service providers who are considered “authorized” personnel who need to know the information to perform business services or market products on our behalf. We also educate our employees about the importance of protecting the privacy and security of confidential personal information. Additionally, we maintain physical, electronic and procedural safeguards that comply with federal and state regulations to guard your personal information.

 

Maintaining Accurate Information. 

We have procedures in place that help us maintain the accuracy of the personally identifiable information that we collect. Please write to us or call if you believe that our information about you is incomplete, out-of-date, or incorrect.

 

SIPC Contact Information. 

You may obtain information about SIPC, including the SIPC brochure, by contacting SIPC. SIPC’s Web site address is (www.sipc.org) and telephone number is (202) 371-8300. You will obtain this information, in writing, at least once each year.

 

Updating Our Privacy Policy. 

We will provide notice of our privacy policy annually, as long as you maintain an ongoing relationship with us. We will also update our policies and procedures when necessary to ensure that your privacy is maintained and that we conduct our business in a way that fulfills our commitment to you. If we make any material changes in our privacy policy, we will provide our customers with an updated notice.

 

Please Contact Us With Any Questions.

Confidentiality is an established hallmark of our business. We understand the need to safeguard the personal information that you disclose to us, and we have an established tradition of discretion and respect for our customers’ privacy. We reinforce this daily in the way we routinely handle sensitive client information as part of our normal business operations. If you have any questions about our privacy policy, please contact us at (949) 295-1580.

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