Privacy Note

Protecting Your Confidential Information

We at Manduca Trading LLC (“Manduca”) value our relationship with each of our customers, and we appreciate the trust that you have placed in us. We recognize that you have concerns about the confidential personal information we obtain about you throughout our relationship. Because protecting your confidential information is important to us, we have adopted a privacy policy which governs how the confidential information we obtain about you is used and maintained. We pledge to protect that information and ensure that it remains private. The information in this notice summarizes the categories of personal information that we collect about you, how that information is handled, and how we protect that information. We do not disclose any nonpublic personal information about our customers to anyone, except as required or permitted by law. Manduca does not sell personal information obtained about you to companies that are not associated with Manduca for the purpose of marketing their products or services to you.

Collection and Use of Personal Information

The privacy policy set forth in this notice applies to Manduca and affiliated companies of Manduca. We collect nonpublic personal information about you from the following sources, solely for the purposes specified:

• Information we receive from you on account applications or other forms to verify your identity , such as name, address, federal tax identification number, income, passport information, assets and similar information. We use this information to administer the accounts we maintain on your behalf, process transactions requested by you, respond to your inquiries, evaluate your investment needs, and identify other products and services that may interest you.
• Information about your transactions with us or our affiliates, such as your account balance, transaction history and payment activity. This information is used to process transactions you request and ensure the accuracy of the records and reports we maintain that relate to your account. We may also collect various other types of data, such as transaction, site navigation and optional survey information, in connection with your use of online services we make available to you, either directly or through other entities. We use this information in order to improve the quality of the services we offer you.
• Information we receive from consumer reporting agencies, such as credit relationships and credit history. We use this information to help determine your eligibility for Manduca products and services, collect or report debts owed to us, and protect our rights and property.

Sharing of Information Within Manduca

The information we collect relating to your transactions and experiences with Manduca or any affiliate may be shared among Manduca’s affiliates. We may also share some or all of the information we receive about you from consumer reporting agencies, such as credit information.

Sharing of Information Outside Manduca

As permitted by law, we may disclose some or all of the information described above with entities that are not affiliated with Manduca for the purpose of servicing your Manduca accounts, improving our services, providing products and services you’ve requested from Manduca, and informing you about products or services available from Manduca that may be of interest to you. Such companies may include:

• Companies that are the source or origin of financial services offered by Manduca, such as banks, FCM's, securities broker-dealers, mutual fund companies and insurance companies.
• Nonfinancial companies, such as companies that perform services on our behalf, e.g., check printers, quote vendors, companies that prepare account statements for us, companies that assist us in communicating or marketing our services.
• Others, such as independent contractors or technical system consultants who program our software, government agencies and regulators, consumer reporting agencies, and other outside entities as permitted or required by applicable laws.

These companies are required to keep your personal information confidential. Also, we may disclose personal information with publishers and other direct marketers of products to the financial services industry, such as newsletter or book publishers and software or trading system developers.

Hyperlinks

Manduca’s website 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 Manduca's. This Website Privacy Statement applies solely to information collected by our websites. Manduca 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.

Right to Opt Out of Information Sharing:

If you prefer that we not disclose your personal information to unaffiliated third parties, you may opt out of those disclosures. That is, you may direct us not to make those disclosures (other than disclosures permitted or required by law). You, however, may not opt out of Personal Information disclosed about you to your FCM(s), or any service provider necessary to effect or process any transaction in your account(s) with us. If you wish to opt out of disclosure to nonaffiliated third parties, you may e-mail us at opt-out@manducatrading.com, or phone us at 312-987-2053, stating that you wish to opt out of all information sharing of your personal information.

Accessing and Revisiting Your Personal Information

We endeavor to keep our customer files complete and accurate. We will give you reasonable access to the information we have about you. Most of this information is contained in account statements that you receive from us and applications that you submit to obtain our products and services. We encourage you to review this information and notify us if you believe any information should be corrected or updated. If you have a question or concern about your personal information or this privacy notice, please contact your Manduca representative.

Protecting the Confidentiality of Your Personal Information

All Manduca employees are instructed to use strict standards of care regarding the confidentiality of your nonpublic personal information as outlined in firm policies. Employees not adhering to our firm policies are subject to disciplinary action. We require outside companies and independent contractors to whom we provide customer information for marketing, servicing or processing to enter into a confidentiality agreement that restricts the use of the information to those purposes. We maintain physical, electronic and procedural safeguards that comply with applicable laws to protect your nonpublic personal information. If you have any questions or comments about our privacy policy, please contact your Manduca broker or sales representative. You may also call Manduca’s Director of Compliance, Bob Maurer, at (312) 987-2053.