Privacy Policy

At Capital Trading Group and its affiliates, maintaining client trust and confidence is a high priority. We understand that you are concerned with how we treat nonpublic personal information ('Client Information') that we obtain from you or from other sources about you in the course of providing you with our products and services. For this reason, we want you to understand how we work to protect your privacy when we collect and use information about you, and the steps we take to safeguard that information.  

General Information About Browsing Capital Trading Group's Websites  

At Capital Trading Group, no account or personal information is retrieved from Capital Trading Group's servers when a client or visitor browses the public (pre-login) areas of our websites. Although Capital Trading Group uses website data to improve the content and services offered to its website visitors, such data is reported on an aggregate, anonymous basis, and we associate no personal information with such gathering of data. Such data may include: how many people visit our websites; the pages they visit; how long they stay on our websites; and the domain name of the site visitors connect from (e.g., yahoo.com).  

A Word About Cookies  

Cookies are small text files that a website transfers to your hard drive or browser to help you move faster through that particular website, or for tracking your website usage. Capital Trading Group does not use cookies to gather personal information such as a person's name or e-mail address. We do, however, use cookies to identify repeat visitors to our websites, to determine the path visitors take to our websites, and to identify visitors who came to Capital Trading Group's websites as a result of a banner ad on a third party website. Please be assured that any information we gather by the use of a cookie is compiled on an aggregate, anonymous basis. Although your browser might allow you to 'reject' cookies, we require that you accept all cookies in order for our websites' features and security mechanisms to function fully.  

Third parties might also create cookies when you access their sites through links posted on our sites. We do not have access to these cookies or any information that these cookies may contain. Please contact the third party site for more information on their policies regarding cookies. Although we expect third parties to adhere to our privacy policies and terms and conditions of use, we are not responsible for the actions or policies of such third parties.  

Capital Trading Group's Security Technology  

Whether you are a Capital Trading Group client or a visitor browsing our websites, and you submit information in one of our online forms, please note that we use Secure Sockets Layer (SSL) encryption technology to protect the information you submit. This technology protects you from having your information intercepted by anyone other than Capital Trading Group while it is being transmitted to us. We work hard to ensure that our websites are secure and that they meet industry standards. In addition to encryption technology, we use other safeguards such as firewalls, authentication systems (e.g., passwords and personal identification numbers) and access control mechanisms to control unauthorized access to systems and data.  

A Word About Hyperlinks  

Capital Trading Group's websites may contain hyperlinks or 'links' to other sites, and other sites may 'link' to our sites. Websites linking to and from our sites may have privacy practices different from Capital Trading Group's. This Website Privacy Statement applies solely to information collected by our websites. Capital Trading Group is not responsible for the privacy policies or the content of sites you link to, and we have no control over the use or protection of information provided by you or collected by those sites. If you elect to link to a co-branded website or to a linked website, you may be asked to provide registration or other information. Please note that the information you are providing is going to a third party, and you should familiarize yourself with the privacy policy provided by that third party.  

Nonpublic Personal Information  

In the event visitors provide Capital Trading Group with nonpublic personal information about themselves (e.g., name, address, phone number, e-mail address) for the purpose of receiving information about our products and services, or if you are a Capital Trading Group client and we obtain from you or from other sources nonpublic personal information about you in the course of providing you with our products and services, the following are the steps we take to safeguard such nonpublic personal information ('Personal Information').  

Security Procedures:  

Capital Trading Group restricts access to Personal Information about you to:

  • Those of our employees and affiliates who need to know that information in order to provide the products and services you receive from us.
  • Those unaffiliated brokers who have introduced you to us ('Introducing Brokers'), commodity trading advisors or investment advisers ('Advisors') you have authorized to enter into transactions on your behalf, and, if directed by those Advisors, entities which provide administrative services to those Advisors.
  • Those unaffiliated third parties whose access to such information is permitted or required by law and who need to know that information in order to assist us in providing you with the products and services you receive from us.
  • Those unaffiliated third parties whose access to such information is necessary in order for Capital Trading Group to engage in joint marketing efforts with such unaffiliated third parties.
  • To protect the security of Personal Information, we maintain physical, electronic, and procedural safeguards that comply with federal standards for guarding the information we collect about you (see Capital Trading Group'S SECURITY TECHNOLOGY, above).  

Information We Collect:  

In providing you with financial products and services, or information about such services, Capital Trading Group may collect the following types of Personal Information:

  • Information we receive from your Introducing Broker (if applicable) or from you on account applications, whether written or electronic, or on other forms (including on-line forms). This information would include your name, address, income, investment experience, and so forth.
  • Information about your transactions with us, our affiliates, or others. This information could include your trading through us, our affiliates and others, your history of meeting margin calls, and your use of the various products and services that we and our affiliates provide.
  • Information about your creditworthiness, credit history, and other information about you that we receive from consumer reporting agencies, our affiliates, your Introducing Broker (if applicable), or providers of other demographic information, such as your purchasing or investment preferences.
  • Information about you obtained in connection with our efforts to protect against fraud or unauthorized use of your account(s) with us.

Information We Disclose:  

Capital Trading Group may disclose to unaffiliated third parties with which Capital Trading Group is engaged in a joint marketing arrangement Personal Information such as:

  • Information we receive from your Introducing Broker or from you on account applications, whether written or electronic, or on other forms. This information would include your name, address, social security number, income, investment experience, and so forth.
  • Information about your transactions with us, our affiliates, or others. This information could include your trading through us, our affiliates and others, your history of meeting margin calls, and your use of the various products and services that we and our affiliates provide.

Categories of Parties to Which We May Disclose:  

  • Capital Trading Group may disclose the types of Personal Information listed above (see INFORMATION WE COLLECT) to the following types of third parties:
  • Companies that perform marketing services on our behalf or to other financial institutions with which we have joint marketing agreements to sell Capital Trading Group products or services.
  • Financial service providers, such as introducing brokers, broker-dealers, futures commission merchants, investment companies, Advisors, and entities, which provide administrative services to Advisors, and commodity pool operators.
  • Publishers and other direct marketers of products related to the financial services industry, such as newsletter or book publishers and software or trading system developers.
  • We may also disclose Personal Information to other nonaffiliated third parties as permitted or required by law, such as in response to a subpoena or legal process or in order to complete a transaction which you initiated and authorized.

Website Privacy Statement Updates:  

Capital Trading Group may, from time to time, make changes to this Website Privacy Statement. We recommend that frequent visitors to our websites reread this Website Privacy Statement periodically to learn of any updates and changes we have made to this Statement. Should you become a Capital Trading Group client by obtaining a user ID and password and completing new account forms on-line, we will notify you of any changes we make to this Statement in the following manner. The first time you log on one of our websites after we have modified our Website Privacy Statement, we will require you to click-through our revised Statement. You will not be able to access your account information or place an order until you agree to the terms of the revised Statement.

Conversations with Capital Trading Group, L.P. Representatives  

As of December 21, 2013, the Commodity Futures Trading Commission Regulation 1.35 (a) began requiring Capital Trading Group, L.P. to keep a record of (and therefore tape record) all oral communications provided or received concerning quotes, solicitations, bids, offers, instructions, trading and prices that lead to the execution of a transaction in a commodity interest and related cash or forward transaction, whether communicated by telephone, voicemail, mobile device, or other digital or electronic media, for a period of one year. Capital Trading Group, L.P. must record such communications regardless of whether it occurred on a firm provided or personal phone. It is Capital Trading Group, L.P.’s Policy that no representative is permitted to speak to a customer concerning quotes, solicitations, bids, offers, instructions, trading and prices that lead to the execution of a transaction in a commodity interest and related cash or forward transaction unless the conversation is done over a device that is recorded using technology provided and maintained by Capital Trading Group, L.P.

Customers and counterparties must consent to the recording of all oral communications that are subject to recording Rules. The receipt of this Privacy Policy is your notice that all conversation between you and a registered associated person of Capital Trading Group, L.P. will be recorded and maintained on file under secure measures as outlined in this notice for a period of one year. Should you object to this recording policy, your will need to notify our office within 10 calendar days of your unwillingness to be subject to your conversations being recorded while speaking with a registered associated person of Capital Trading Group, L.P. After this 10 calendar day period, your silence will be accepted as your consent to this policy.

 

 

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