Privacy Policy

The following describes how ClearList Holdings LLC and its affiliates, including, but not limited to ClearList LLC, Member: FINRA & SIPC, ClearList Securities LLC: Member FINRA & SIPC and ClearList Capital LLC (collectively “ClearList”), handles your personal information, and what steps we take to protect your privacy. This policy applies to current and former customers. We do not use your personal information for marketing purposes.

ACCESSING INFORMATION

Access to customer information is authorized for official business purposes only. ClearList will endeavor to store personal information transmitted by you in connection with your use of the ClearList website (the “Site”) or other ClearList related businesses (collectively, “ClearList Business”) in a secure environment that is suitable to the types of information being processed. Access to this information is restricted to personnel who have a need to know such information in order to conduct ClearList Business or who otherwise need to utilize this information in accordance with the provisions of this Privacy Policy. (References to “you” and “your” are references to you and/or your employer, as appropriate in the context.)

Information that may be collected

In order to access certain portions of the Site or participate in ClearList Business, ClearList may require you to provide certain personal information, including your name, employer, title, social security number, certain identifying documents such as your driver’s license, telephone number and e-mail address. Without this required data, we may not be able to proceed with your request, instructions or other requirements.

While you are within the Site our web servers may recognize, among other things, your: (a) domain name; (b) ISP’s domain name; (c) IP address; (d) browser type; and (e) operating system. We may also record certain “clickstream” information regarding your activity within the Site (including, for example, which pages you view when accessing the Site). While you are within the Site, our web servers may also place cookies on your computer in order to recognize you as a ClearList Site user, to track your use of ClearList products and services and your acceptance of terms of use, disclaimers and similar matters.

Additionally, telephone conversations and electronic communications, such as e-mails and instant messaging, between you and ClearList in connection with ClearList Business may be recorded. ClearList may also collect information about you to help conduct ClearList Business, provide customer service, offer new products or services, and fulfill legal and regulatory requirements. The type of information provide to ClearList varies according to the type of ClearList business being conducted but is not limited to:

  • Information included on your application, subscription documents, and related forms (such as name, address, Social Security number, net worth, and income)
  • Information about your relationships with the Firm (such as prior investments)

How your information may be used by ClearList

Information collected from you and recorded about you in connection with ClearList Business, including all personal information, clickstream information, telephone conversations and electronic communications, may be retained by ClearList and associated with your name and other information collected about you by ClearList.

Such information may be used by ClearList or its agents (e.g., technology and operational support service providers, including, but not limited to, Fundamental Interactions Inc., and Ascent Fund Services, and financial service providers, including, but not limited to, ClearList LLC, ClearList Securities LLC, ClearList Capital LLC, or custodians/clearing agents or fund administrators: (a) in order to allow us to provide you with the products and services included within ClearList Business; (b) in order for us to provide you with access to or from other Web sites or services which contain additional, and sometimes co-mingled products and services; (c) for system development purposes, (d) in connection with any subscriber, user or customer agreement (“User Agreement”) between you and ClearList, between you and one of our agents, or as otherwise agreed by you; (e) in connection with our client management systems; and (f) to satisfy legal and regulatory compliance requirements (collectively, “Permitted Uses”).

To whom and where information may be disclosed

We may transfer or disclose your personal information to other entities as contemplated by the permitted uses. For instance, we may disclose your personal information to our agents or other third parties who are contracted to perform services on behalf of ClearList, such as those who assist ClearList in bringing you the Site and providing you with certain services, features and functionality included within or accessible via the Site. ClearList or its affiliates or agents may also be required to disclose your personal information to governmental or regulatory authorities or self-regulatory organizations in response to regulatory inquiries or to comply with applicable laws, rules, regulations, orders, subpoenas or other legal processes.

ClearList may provide or license to third parties trading or other data reflecting, for example, the activity of users of the Site or the use of products or services offered, but ClearList will not identify you as the source of such data.

SECURITY STANDARDS

ClearList continues to assess new technology to evaluate its ability to provide additional protection of your personal information. We safeguard this information in accordance with federal standards and established security standards and procedures. Some of the measures we implement include use of physical, electronic, and procedural safeguards.

Consent

By participating in ClearList Business, using the Site and providing any information that may be required, invited or otherwise collected by us as set out above, you freely consent to ClearList and its affiliates using your information or disclosing your information to third parties for the purposes set out herein.

Revisions to this Privacy Policy

ClearList may revise this Privacy Policy at any time at its sole discretion, and you should review this Privacy Policy whenever accessing or using the Site. Your use of the Site after the posting of any such revisions to the Privacy Policy will constitute your acceptance of such revisions.

How to Contact Us

Should you have any questions or concerns about the information we hold about you, or if you want to withdraw your consent, please contact us at compliance@clearlist.com and put “Privacy Policy” in the subject line.

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