PRIVACY POLICY
PRIVACY STATEMENT OF WHITE MOUNTAIN CAPITAL, LLC
The confidentiality of client information is an important concern of White Mountain Capital, LLC (White Mountain Capital). We take precautions to safeguard personal client information at all times and we will remain vigilant in protecting that information. The provisions of this privacy notice will apply to former clients as well as current clients.
White Mountain Capital collects personal information about you that is necessary to provide financial products or services. We may obtain this information from the following sources:
Information we receive from you on account applications, forms and other materials that you provide to us, whether in writing, in person, by telephone or by any other means. This information may include your name, address, telephone number, social security number, occupation, assets and income. Information about your transactions with us or a non-affiliated third party including: account balances, payment history, electronic communications and account activity.
Information we receive from a consumer-reporting agency, such as your credit bureau reports and other information relating to your creditworthiness.
White Mountain Capital does not share customer non-public information with non-affiliated companies or non-exempt service providers. We will only disclose certain information about you, as permitted by law, under the following circumstances:
* Where, we believe, in good faith that disclosure is required under law to cooperate with regulators or law enforcement authorities.
* To consumer reporting agencies.
* To our service providers to help us process your application or service your accounts. These service providers, in turn, are required to protect the confidentiality and security of any information we give to them and may not reuse it for any other purpose.
If you prefer that we do not disclose non-public personal information about you to non-affiliated third parties, you may opt out of these disclosures, that is, you may direct us not to make these disclosures (other than disclosures permitted by law). If you wish to opt out of disclosures to non-affiliated third parties, you may call us at (212) 509-0313 or submit a written request to opt out.
White Mountain Capital restricts access of your personal account(s) and information to those employees who require access to that information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with the industry standards to safeguard your nonpublic personal information such as password protection for computerized information, access to customer information by authorized personnel and ensuring that all third party providers have privacy policies. Third parties who have access to such personal information must agree to follow appropriate standards of security and confidentiality.
Account Privacy Information
| FACTS | WHAT DOES WHITE MOUNTAIN CAPITAL, LLC DO WITH YOUR PERSONAL INFORMATION? |
| Why? | Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do. |
| What? | The types of personal information we collect and share depend on the product or service you have with us. This information can include: Social Security number and Government-issued ID numbers Date of Birth and Residential & Employment Data Transaction History and Financial Data and other data |
| How? | All financial companies need to share clients’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their clients’ personal information; the reasons White Mountain Capital chooses to share; and whether you can limit this sharing. |
| Reasons we can share your personal information | Does White Mountain Capital, LLC share? | Can you limit this sharing? |
| For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus | YES | NO |
| For our marketing purposes – to offer our products and services to you | NO | N/A |
| For joint marketing with other financial companies | NO | N/A |
| For our affiliates’ everyday business purposes – information about your transactions and experiences | YES | NO |
| For our affiliates’ everyday business purposes – information about your creditworthiness | YES | YES |
| For nonaffiliates to market to you | NO | N/A |
| To limit our sharing |
Call 212-509-0313 If you are a new customer, we can begin sharing your information 3 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing. |
| Questions? | Call 212-509-0313 |
| Who we are | |
| Who is providing this notice? | White Mountain Capital, LLC |
| What we do | |
| How does White Mountain Capital protect my personal information? | To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. |
| How does White Mountain Capital collect my personal information? | We collect your personal information, for example, when you: open an account or make changes to your profile make a trade or request information on a product or service complete applications, among other times |
| Why can’t I limit all sharing? | Federal law gives you the right to limit only: sharing for affiliates’ everyday business purposes – information about your creditworthiness affiliates from using your information to market to you sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. |
| What happens when I limit sharing for an account I hold jointly with someone else? | Sharing on the entire account is limited. |
| Definitions | |
| Affiliates | Companies related by common ownership or control. They can be financial and nonfinancial companies. |
| Nonaffiliates | Companies not related by common ownership or control. They can be financial and nonfinancial companies. |
| Joint marketing | A formal agreement between nonaffiliated financial companies that together market financial products or services to you. |
| Other important information |
| As an introducing broker, White Mountain Capital will share your personal information with our clearing firm, Hilltop Securities Inc (SWST). SWST handles transaction processing, clearing and custody and provides statements and confirmations. |
White Mountain Capital LLC website and its links (together the “Web Site”) are presented for informational purposes only. The Web Site is neither offering or soliciting to buy securities of any kind nor is it giving any type of investment advice upon which any type of investment advice upon which any person should rely without giving due consideration to other sources of information. White Mountain Capital LLC is a registered Broker-Dealer and a member of the Financial Industry Regulatory Authority (FINRA) and the Securities Investor Protection Corporation (SIPC). All retail brokerage customer securities transactions are cleared through Hilltop Securities Inc (SWST).
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