• AML POLICY
• BUSINESS CONTINUITY PLAN
• CUSTOMER COMPLAINT NOTICE
This privacy notice complies with the Gramm-Leach-Bliley Act and federal regulations governing the privacy of financial information applicable to our clients. The term “InvestX,” “we,” and “us” includes InvestX Markets LLC, and its parents, successors, affiliates and subsidiaries.
We are committed to providing our clients with quality service. While collecting information about you is essential to meet your needs, we recognize the importance of handling your personal information with care. Accordingly, we have established this Notice of Privacy and related policies.
CONFIDENTIALITY AND SECURITY OF YOUR INFORMATION
We maintain appropriate physical, electronic, and procedural safeguards to protect the security and confidentiality of your nonpublic personal information. We educate our employees about the terms of this Notice and the importance of customer privacy. We restrict access to nonpublic personal information about you to those employees and others who need to know that information to provide services to you, to maintain your accounts, or conduct our business.
INFORMATION WE COLLECT ABOUT YOU
Collecting information from you is essential to our ability to offer quality services. As part of that process, we may collect nonpublic information about you from the following sources:
• Information we receive from you on applications and other forms;
• Information about your transactions with us;
• Based upon the services provided, information we receive from consumer reporting agencies, government agencies and from your agent banks and prime brokers where applicable; and
• Information that is used to facilitate emails from you.
Using Cookies, Automatic Data Collection, And Related Technologies
We may collect information on how the InvestX website is accesses and used (“usage data”). Usage data may include information such as your computer’s Internet Protocol address (“IP address”), browser type, browser version, the pages of our service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. We also collect information, such as anonymous usage statistics, by using cookies, server logs, and other similar technology as you use the website. Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do that, the website may not work properly.
By using the service, you are authorizing us to gather, parse, and retain data related to the provision of the service.
CATEGORIES OF INFORMATION WE DISCLOSE AND TO WHOM
We do not disclose any information about our clients or former clients to anyone, except to affiliates and subsidiaries and as permitted or required by law. We may disclose the types of information listed below to companies that help us conduct our business, that perform administrative or other services on our behalf, or other financial institutions with which we now or may have joint marketing agreements:
• Information we receive from you on applications and other forms, such as your name, address, Social Security number (if an individual), assets, income and beneficiaries;
• Information about your transactions with us, or others; and
• Information we receive from a consumer reporting agency, government agencies and from your agent banks and prime brokers where applicable, and from other sources, such as information concerning credit worthiness and history, and certain information requested pursuant to US Patriot Act anti-money laundering prevention rules and regulations.
We may use aggregate information for any purpose.
Internal and Service-Related Usage
We use information, including personal information, for internal and service-related purposes and may provide it to third parties to allow us to facilitate the service. We may use and retain any data we collect to provide and improve our services.
Information Validation and Assessment
We may use the information you provide to assess its accuracy and your financial condition, including by performing credit checks.
We may send mail to the address, email to the email address, or call you at the telephone number you provide to us for informational and operational purposes, such as to provide updates about the service and perform customer service.
We may use information, including personal information, to provide online advertising on the service from us and our affiliates and to facilitate transmittal of information we think may be useful or relevant to you.
We may allow access to other data collected by the service to enable the delivery of online advertising on or off this service or to otherwise facilitate transmittal of information we think may be useful or relevant to you.
We may anonymize and aggregate data collected through the service and use it for any purpose.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your information
We give you many choices regarding our use and disclosure of your information for marketing purposes. You may opt-out from:
• Receiving electronic communications from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by following the instructions at the bottom of each email or contact us.
• Our sharing of your information with affiliates for their direct marketing purposes: If you would prefer that we not share your information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt-out of this sharing by contacting us.
• Our sharing of your information with unaffiliated third parties for their direct marketing purposes: If you would prefer that we not share your information on a going-forward basis with unaffiliated third parties for their direct marketing purposes, you may opt-out of this sharing by contacting us.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
EUROPEAN UNION’S GDPR RIGHTS
Residents of the European Union have rights afforded to them by The General Data Protection Regulation (“GDPR”). These rights include:
• The right to be informed – To understand how the personal data you provide to us is used.
• The right to access – To a copy of your personal data that we have and use.
• The right to rectification – To correct any inaccurate or incomplete personal data.
• The right to erasure – To erasure your personal data, when there is no compelling reason for us to continue to have it.
• The right to restrict processing – To restrict the use of your personal data, when there is not compelling reason for use to continue to use it.
• The right to data portability – To have your personal data available to you in a machine-readable, transportable format.
• The right to object – To object to direct marketing.
• Rights related to automated decision and profiling – To have decisions made by a human.
For more information about your rights under GDPR, or for a copy of the Record of Processing Activities, please reach out to us through the contact information provided at the bottom of the page. We will not charge you for you exercising your rights under GDPR.
MERGER, SALE, OR OTHER ASSET TRANSFERS
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of InvestX’s assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. We cannot control how such entities may use or disclose such information.
We may also disclose your personal information with your permission.
By using the Service or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the service. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the website or sending an email to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at firstname.lastname@example.org.
By using the Service, you will transfer data to the United States.
Our service does not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.
UPDATE YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION
NEW USES OF PERSONAL INFORMATION
FOR CALIFORNIA RESIDENTS
The California Consumer Privacy Act of 2018 (“CCPA”), grants, commencing on January 1, 2020, a California resident (“Consumer”) various rights with regard to personal information relating to that Consumer that is held by a business, including the right to request a business to delete any personal information about the Consumer collected by the business, and requires the business to comply with a verifiable Consumer request to that effect.
A Consumer will have the right to request that InvestX disclose to that Consumer the categories and specific pieces of personal information the registered InvestX entity has collected. Such disclosure must be made only upon the receipt of a verifiable Consumer request.
A Consumer shall have the right to request that InvestX delete any personal information about the Consumer which InvestX has collected from the Consumer. Upon receipt of a verifiable Consumer request from a consumer to delete the Consumer’s personal information, InvestX shall delete the Consumer’s personal information from its records and direct any service providers to delete the Consumer’s personal information from their records, unless otherwise restricted by applicable law.
A Consumer shall have the right to request that a business that collects personal information about the Consumer disclose to the Consumer the following:
1. The categories of personal information it has collected about that Consumer.
2. The categories of sources from which the personal information is collected.
3. The business or commercial purpose for collecting or selling personal information.
4. The categories of third parties with whom the business shares personal information.
5. The specific pieces of personal information it has collected about that Consumer.
ANTI-MONEY LAUNDERING CUSTOMER IDENTITY VERIFICATION NOTICE
To help the government fight the funding of terrorism and money laundering activities, federal law requires broker-dealer firms to obtain, verify, and record information that identifies each person who opens an account.
What types of information will you need to provide?
For an individual, when you open an account, InvestX Markets LLC are required to collect information such as the following from you: Your name, date of birth, address, identification number: U.S. Citizen: taxpayer identification number (social security number or employer identification number) or Non-U.S. Citizen: taxpayer identification number, passport number, and country of issuance, alien identification card number, or government-issued identification showing nationality, residence, and a photograph of you. You may also need to show your driver’s license or other identifying documents.
For an entity, when an account is opened, we are required to collect information such as the following from the entity: documents showing the existence of the entity, such as certified articles of incorporation, a government-issued business license, a partnership agreement, or a trust instrument.
We may, under the following circumstances, rely on the performance by another financial institution (including an affiliate) of some or all of the elements of our customer identification program with respect to any customer that is opening an account or has established an account or similar business relationship with the other financial institution to provide or engage in services, dealings, or other financial transactions:
Such reliance is reasonable under the circumstances, when the other financial institution is subject to a rule implementing the anti-money laundering compliance program requirements and is regulated by a Federal functional regulator and when the other financial institution has entered into a contract with us requiring it to certify annually to us that it has implemented its anti-money laundering program, and that it will perform (or its agent will perform) specified requirements of the customer identification program.
BUSINESS CONTINUITY PLAN
SUMMARY DISCLOSURE STATEMENT
InvestX Markets LLC (“InvestX”), pursuant to Financial Industry Regulatory Authority, Inc. (“FINRA”) rules, has created a Business Continuity Plan, to address and guide our response to and recovery from Significant Business Disruptions (“SBDs”). Copies of this Summary Disclosure Statement shall be given to all clients at the time they open their accounts with InvestX. InvestX’s Business Continuity Plan is subject to modification and an updated summary will be promptly e- mailed to our clients. Alternatively, clients may obtain updated summaries by requesting a written copy by mail or fax.
In all of the following scenarios, InvestX plans to continue business and our planned recovery time, depending upon the time of occurrence, should not exceed 24 hours from the time of the declaration of the SBD. Staff, telephone calls, and e-mails will return to their original location upon full restoration of service.
Disruption to a single building or our Firm’s main or branch offices
If a disruption occurs at our main office located at 650 – 1090 West Georgia Street, Vancouver, BC V6E 3V7, Canada or branch office located at 19 Fulton Street, Suite 307, New York, NY 10038, we will move our staff from affected offices to the home of each individual Associated Person.
Disruption to a business district
If a disruption occurs in our business district affecting our main or branch offices, we will move our staff from affected offices to the home of each individual Associated Person. These locations shall be outside the business district.
City-wide business disruption
If a disruption occurs in our city-wide area that affects our main or branch offices, we will move our staff from affected offices to the home of each individual Associated Person. These locations shall be outside the city-wide area.
If a regional disruption occurs that affects our main or branch offices, we will move our staff from affected offices to the home of each individual Associated Person.
InvestX has also contracted with various entities to ensure that sensitive information is made redundant at back-up facilities. However, due to the nature of such information we do not disclose the specific location of any back-up facilities, any proprietary information contained in our Business Continuity Plan or the parties with whom we have back-up arrangements.
Please call if you should you have any questions at 1844 246 4556.
CUSTOMER COMPLAINT NOTICE – SEC Rule 17a-3(a)(18)(ii) DISCLOSURE STATEMENT
InvestX Markets LLC in accordance with Rule 17a-3(a)(18)(ii), is furnishing this statement to provide you with a name, telephone number and address, if you ever need to report or notify us of a possible complaint. If, for any reason, you feel you have a complaint, please contact our offices immediately, either by mail at InvestX Markets LLC 650-1090 West Georgia Street, Vancouver, BC V6E 3V7, Canada Attention: Compliance Department or 1844 246 4556 and ask to speak with our Compliance Officer.
SIPC AND FINRA NOTIFICATION
InvestX Markets LLC is a member of the Securities Investor Protection Corporation (SIPC), which protects securities of its members up to $500,000 (including $250,000 for claims for cash). However, we do not hold customer funds and securities. Funds and securities held by outside institutions are not covered by our SIPC protection.
All customers are advised that information about SIPC, including the SIPC brochure, may be obtained by contacting SIPC. SIPC may be contacted by phone, email or regular mail:
For more detailed information please visit the SIPC website at www.sipc.org