OUR COMMITMENT TO YOUR PRIVACY: EarlyBirdCapital, Inc. (EBC) has a long-standing policy of protecting the confidentiality and security of information we collect about our customers. We will not share non-public information about you (“Information”) with third parties without your consent, except for the specific purposes described below. This notice 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 we require to deliver superior service to you. Such service includes maintaining your accounts with us, processing transactions requested by you and administering our business.
HOW WE GATHER INFORMATION: We get most Information directly from you when you apply for, access and use financial products and services offered by EBC – whether in person, by telephone or electronically. We may verify this information or get additional information from consumer reporting agencies or public sources. This Information may relate to your finances, employment, avocations or other personal characteristics, as well as interactions with or through EBC or others.
HOW WE PROTECT INFORMATION: We may disclose any Information as directed by you or when we believe it necessary for the conduct of our business, or where law requires disclosure. For example, Information may be disclosed for audit or research purposes, to attorneys or other professionals, or to law enforcement and regulatory agencies, for example, 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 or data maintenance or processing services for us (ii) to facilitate the processing of transactions effected for you, (iii), to assist us in offering products and services to you, (iv) for credit review and reporting purposes, and/or (v) to comply with regulatory obligations such as compliance or financial audits or exams. Except in those specific, limited situations, without your consent, we do not make disclosures of Information to other companies 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. It is EBC’s policy to require all third parties other than your broker, to receive any Information to sign strict confidentiality agreements. EBC employees are required to comply with the Firm’s Confidentially Policy and must annually acknowledge responsibility for complying with the policy.
Access to and Correction of Information: If you desire to review any file we may maintain for your personal Information, please contact your broker. If your broker or you notify us that any 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 future disclosures of the disputed Information. Information collected in connection with, or in anticipation of, any claim or legal proceeding will not be made available.
EBC takes several measures to protect customer information and prevent identity theft. All account documents and customer information is kept in locked file cabinets. All computer available account information is password protected and protected by firewalls. Any document which is no longer needed or no longer must be kept under SEC Rules 17a-3 and 17a-4 containing any personal information is destroyed prior to leaving EBC offices.