Privacy & Security

Your privacy is important to SSV: In the course of serving you as an individual client or as someone associated with an institutional client, SSV may obtain personal information about you. 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.

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 SSV during the course of your relationship with us. We may also collect information about your transactions and experiences with SSV relating to the products and services SSV provides. In addition, depending on the products or services you require, SSV 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. recording of telephone calls and monitoring e-mails). In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used for compliance or security purposes.

Our use of your personal information: We may use your personal information to:

• Administer, operate, facilitate and manage your relationship and/or account with SSV. 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 SSV; and
• Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

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

Disclosures of your personal information within SSV: In order to provide efficient and reliable services and to improve product and service options available to you, more than one entity within SSV may be given, or given access to, your personal information.

Disclosures of your personal information to third parties: SSV does not disclose your personal information to third parties, except as described in this policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your account or facilitate your transactions with SSV, including those that provide professional, legal or accounting advice to SSV. Non-affiliated companies that assist SSV in providing services to you are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only for the purposes that SSV dictates.

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.