Privacy

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 firms 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:

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);
as required by law or legal process; or
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.