Sutter Securities, Inc.
Privacy Policy

Your privacy is important to Sutter Securities Group, Inc. (“Sutter”) and its affiliates

In the course of serving our clients, Sutter may obtain personal information about such clients. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.

This policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy. As used throughout this policy, the term “Sutter” refers to Sutter Securities Group, Inc. and its affiliates.

The sources of information

The personal information we collect about you comes primarily from the account applications or other forms and materials you submit to Sutter during the course of your relationship with us. We may also collect information about your transactions and experiences with Sutter relating to the services Sutter provides. In addition, depending on the services you require, Sutter may obtain additional information about you, such as your credit history, from consumer reporting agencies.

Finally, in the provision of financial services to you and subject to strict compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g. e-mail monitoring). In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used for compliance or security purposes.

The information we have about you

If you deal with Sutter in your individual capacity (e.g. as a private client), or as a settlor/trustee/beneficiary of a trust, or as an owner or principal of a company or other investment vehicle established to invest on your behalf or on behalf of your family, etc., the typical information we collect about you may include (in addition to any other information as may be determined on a case-by-case basis):

• Your full name, phone number, physical address, email address, organization, and other contact details;
• Extensive financial information, including source of wealth, investment experience and objectives, risk tolerance and, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources; and
• A personal identifier such as, depending on your country of residence, your Social Security Number, National Insurance Number, Tax File Number, etc.

Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in our being unable to open or maintain your account or to provide services to you. While we make every effort to ensure that all information we hold about our clients is accurate, complete and up to date, we rely on our clients promptly notifying us if there are any changes to their personal information.

Our use of your personal information

We may use your personal information to:

• Administer, operate, facilitate and manage your relationship and/or account with Sutter. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively;
• Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship and/or account;
• Provide you with information (such as investment research), recommendations, or advice concerning products and services offered by Sutter; and
• Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

If your relationship with Sutter ends, Sutter will continue to treat your personal information, to the extent we retain it, as described in this policy.

Disclosures of your personal information within Sutter

In order to provide efficient and reliable services and to improve product and service options available to you, more than one entity within Sutter may be given, or given access to, your personal information. For example, one Sutter entity might share your information with another in order to facilitate settlement of your transactions or the maintenance of your accounts, or as part of its arranging for the performance of specialized services such as US and international brokerage, asset management and advisory services. When so sharing your personal information, we adhere to applicable legal and industry standards regarding the protection of personal information. Additional information on how your personal information is protected while within Sutter is provided below, under Information Security: How We Protect Your Privacy.

Disclosures of your personal information to third parties

Sutter does not disclose your personal information to third parties, except as described in this policy. Third party disclosures may include sharing such information with investment partners (e.g. deal sponsors), other financial institutions (e.g. lenders requiring such information pursuant to regulatory requirements) and/or nonaffiliated companies that perform support services for your account or facilitate your transactions with Sutter, including those that provide professional, legal or accounting advice to Sutter. Each such third party is required to maintain the confidentiality of such information to the extent received and to use your personal information only in the course of providing the services, and only for the purposes, dictated by Sutter.

We may also disclose your personal information to fulfill your instructions, to protect our rights and interests and those of our business partners or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations; for instance, when responding to a subpoena or similar legal process, to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities or with organizations such as exchanges and clearinghouses.

You should know that Sutter will not sell your personal information.

Information security: How we protect your privacy

Sutter is committed to protecting the privacy and confidentiality of your personal information. We limit access to your personal information to authorized Sutter employees or agents and, as described above in Disclosures of Your Personal Information to Third Parties, third parties are held to stringent standards of privacy. We also maintain physical, electronic and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure. Some of the other central features of our information security program are:

• A dedicated group within Sutter that designs, implements and provides oversight to our information security program;
• The use of specialized technology such as firewalls;
• Testing of the security and operability of products and services before they are introduced to the Internet, as well as ongoing scanning for publicly known vulnerabilities in the technology;
• Internal and external reviews of our Internet sites and services;
• Monitoring of our systems infrastructure to detect weaknesses and potential intrusions;
• Implementing controls to identify, authenticate and authorize access to various systems or sites;
• Protecting information during transmission through various means including, where appropriate, encryption; and
• Providing Sutter personnel with relevant training and continually updating our security practices in light of new risks and developments in technology.

Privacy and the Internet

The following additional information will be of interest to you as a visitor to this site:

• Users of suttersecurities.com are required to identify and authenticate themselves prior to accessing our services. Generally, identification and authentication take place through the use of your user name and a password.
• Suttersecurities.com is built upon a secure infrastructure with multiple layers of protection. Sutter Securities Group, Inc. and its affiliates use industry standard encryption technologies to protect your information from external compromise.
• We may collect certain aggregate and non-personal information when you visit the Suttersecurities.com. We may collect this information through “cookie” technology. Cookies are bits of text that can be placed on your computer’s hard drive when you visit certain websites. Cookies may enhance your online experience by saving your preferences while you are visiting a particular website. The “help” portion of the toolbar on most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Remember, though, without cookies, you may not be able to take full advantage of all of the Suttersecurities.com features.
• Sutter may make available on this Web site third party applications such as content linking or sharing facilities. Information collected by providers of such applications is governed by their privacy policies.
• Our Web sites are not currently configured to respond to “do not track” signals or similar mechanisms.

Other privacy policies or statements; changes to policy; contact

As used throughout this policy, the term “Sutter” refers to Sutter Securities Group, Inc. and its affiliates. This policy provides a general statement of the ways in which Sutter protects your personal information. You may, however, in connection with specific products or services offered by Sutter, be provided with privacy policies or statements that supplement this policy. This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised policy will be effective immediately upon posting to our Web site. This version of the Policy is effective July 16, 2019. If you require further information regarding our privacy policies and practices please contact us.