PRIVACY NOTICE

The U.S. Securities and Exchange Commission (SEC) has approved regulations that require financial institutions to develop and disclose privacy policies regarding the handling of information about clients.

To comply with the SEC regulations, we are sending you a copy of this Privacy Notice. It outlines the practices Source Trading follows with respect to collecting and using client information. In the future, an updated Privacy Notice will be sent to all clients annually.

As a matter of policy, Source Trading has always acted with extreme caution to protect clients’ privacy. Source Trading gathers client information from new account forms, applications, contracts and other forms that are received in the normal course of business. Information about transactions with Source Trading and its affiliates is also collected. This information is used to open accounts, process requests and transactions, and communicate information about Source Trading. In order to service accounts and effect transactions, Source Trading sometimes provides account specific information to other independent firms that specialize in providing these services. Source Trading requires these other independent firms to protect the confidentiality of the information and to use it only for the purpose for which the disclosure is made. Source Trading does not disclose any non-public information to other independent firms, organizations, or individuals unless directed to do so by a client.

Within Source Trading, access to non-public information about clients is restricted to employees who need to know the information to provide products or services to the client. Source Trading maintains physical, electronic and procedural safeguards that comply with federal standards to guard client information.

The privacy policies described in this notice are adhered to for both existing and former clients of Source Trading.