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Dawson
James Securities, Inc.
Pursuant to Title V of the Gramm-Leach-Bliley Act and United States
Securities and Exchange Commission (“SEC”) Regulation S-P (17 CFR
248.1-248.30), this document sets forth the Privacy Policy of Dawson
James Securities, Inc. (DJSI) concerning the privacy interests of
individual consumers and customer’s (described below and hereinafter
referred to as “customers”). DJSI is a securities Broker Dealer
registered with the SEC. Among its other securities related
memberships and associations, DJSI is a member of the Financial
Industry Regulatory Authority (“FINRA”). DJSI’s principal business is
to act as fully disclosed securities Broker Dealer (BD) in accordance
with all laws, rules and regulations applicable to a securities BD and
the business conducted by a securities BD. As a BD DJSI’s principal
business is to facilitate execution of orders received both on a
solicited and unsolicited basis for both its institutional and
non-institutional clients. DJSI has clearing agreements with National
Financial Services LLC (“NFS”) and Sterne Agee Clearing (“SAL”) who
provide certain limited and defined “back office” securities clearing,
custodial and processing services.
In its capacity as a securities BD, DJSI receives and/or comes into
contact with certain nonpublic personal information concerning its
current and/or former customers, including but not limited to
certain non public personal information related to
the securities account(s) that said customers open and/or maintain
with DJSI. Any and all such nonpublic personal information related to
such customers and/or such customers’ securities account(s) is
hereinafter referred to as “nonpublic personal information”. DJSI
receives and/or comes into contact with the nonpublic personal
information only for purposes of conducting its business as described
above. For convenience herein, “you” or “your” refers to any and all
customer(s) described above.
DJSI DOES NOT SELL YOUR NONPUBLIC PERSONAL INFORMATION
In conducting its business as described above, DJSI collects (or may
collect), for example, the following types of nonpublic personal
information:
- Information about you: (1) information you provide in connection
with securities account, margin loan, debit card or any other
financial product or service, whether in writing, in person, by
telephone, electronically or by any other means, such as your name,
address, social security number, tax ID number, assets, income,
investment objectives, financial situation and debt; and (2)
information DJSI obtains (or may obtain) for the purpose of tax
reporting to you and to various agencies to which DJSI reports as
required by law, including disclosures on various Internal Revenue
Service (IRS) forms that DJSI and/or its clearing firm collects for
tax reporting purposes.
- Information about your securities and/or other transactions: (1)
information DJSI collects and relates to account balance, payment
history, trading activity and any other transactions concerning which
DJSI provides brokerage services; (2) information DJSI collects as
part of servicing your account(s), as a BD; and (3) information DJSI
may collect through an internet “cookie” (an information collecting device
from a web server).
- Information about your transactions with nonaffiliated third
parties: (1) information from nonaffiliated third parties pursuant to
law, rules, regulations, standard securities industry practice and/or
legal process, including information and/or documents received,
shared, produced or provided in connection with a subpoena, discovery
request or other legal process compelling production; and (2)
information from non affiliated third parties related to servicing
your account for purposes of providing securities BD services.
- Information from a consumer reporting agency: (1) information from a
consumer reporting agency regarding your creditworthiness or credit
history or other information with regards to margin lending or other
financial transactions; (2) information about the fact that you are a
customer of DJSI; and (3) information from other outside sources
regarding their employment of, credit to or other relationship with
you, or verifying representations made by you, such as your employment
history, loan or credit card balances.
NONPUBLIC PERSONAL INFORMATION DISCLOSED TO AFFILIATES AND
NONAFFILIATED THIRD PARTIES
DJSI discloses to its affiliates and nonaffiliated third parties
nonpublic personal information only in connection with DJSI providing
financial services. Such disclosures include, among other things,
information related to transactions, settlement, billing and payment.
Such disclosures may be provided to affiliates and nonaffiliated third
parties:
(i)as required or necessary to carry out fully and properly the
securities business of DJSI (such as, for example, disclosures to
affiliated and nonaffiliated third party service providers supplying
to DJSI computer related, document processing and delivery, and data
maintenance or processing services, and disclosures to nonaffiliated
third parties such as clearing agencies and entities); (ii) as
required by law or legal process; or (iii) with your consent.
FORMER CUSTOMERS
DJSI will disclose nonpublic personal information about the former
customers of DJSI only as permitted and/or required by law or legal
process, or with your consent.
CONFIDENTIALITY AND SECURITY OF NONPUBLIC PERSONAL INFORMATION
DJSI is committed to implementing and maintaining commercially
reasonable and appropriate measures to maintain your nonpublic
personal information in a secure and confidential fashion. DJSI’s
information and security procedures include, but are not limited to,
the following features:
- Access controls on customer information systems, including controls
to authenticate and permit access only to authorized individuals and
controls to prevent DJSI employees from providing nonpublic
information to unauthorized individuals who may seek to obtain this
information through fraudulent means.
- Physical access restrictions at locations containing nonpublic
personal information.
- Stringent pre-employment screening, including fingerprinting, and
segregation of duties for DJSI employees with responsibilities for or
access to nonpublic information.
DJSI regularly reviews, revises and updates its information security
program to account for changes in technology. DJSI reserves the right
to change this Privacy Policy at any time.
The policies described above all also applicable to the DJSI affiliates, Dawson James Financial Services, Inc. and Dawson James Asset Management.
RULE 606.
PRIVACY PLEDGE.
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