CFS believes that the privacy and
security of an individual’s or company’s financial information is of utmost importance. Our most
valued assets are our relationships with our Customers, and therefore, we take your privacy
concerns very seriously. As an entity regulated by the Commodity Futures Trading Commission
(“CFTC”) and a member of the NFA, we adhere to the privacy and security standards that
are prescribed by the CFTC. We apply the following policies with respect to all of our Customers.
1.
Information Collection. To serve our Customers better, we collect certain
financial information on our Customers. In
the case of individuals, we may collect non-public personal financial information about you
from the following sources:
- Information we receive from you on the Account Application,
the Investment Risk Profile, and the Management
Agreement.
- Information about your transactions with CFS.
- Credit information from a consumer reporting agency (only
with Customer’s permission).
2.
Information Disclosure. CFS does
not disclose any of your non-public personal information to nonaffiliated third
parties except as permitted by law. The law permits disclosure of your non-public personal information
to nonaffiliated third parties in certain situations – generally with respect to effecting,
administering, enforcing, or servicing a transaction. From time to time, CFS and our affiliates
may share your non-public personal information with one another in
order for us to better serve you as our Customer. The non-public personal information that we may
disclose to one another as affiliates includes, but is not limited to: (a) application and account
opening information, including names, addresses, etc; (b) transaction history; (c) credit
information.
3.
Disclosure of Former Customer Information. CFS does not disclose any non-public personal information of former Customers,
except as may be required by law. Thus, should you close your Account and become an
inactive/former Customer, we will adhere to the measures delineated in this Privacy Policy.
4.
Information Safeguards. CFS maintains physical, electronic and procedural
safeguards to guard your non-public
personal information. As a result, only authorized employees who need to know your
information in order to provide you with services will have access to your non-public personal
information. We restrict the access of authorized employees to non-public personal information
for business purposes only. Those safeguards are used by all CFS affiliates.