SMArtX, does not disclose nonpublic personal information about current or former participant platform clients to third parties other than as described below.  The Platform, uses Straight Through Processing and does not collect sensitive information about clients (such as social security number, assets and income) from its user registration process, its discussions with clients, or from any documents that clients may deliver to the firm, while providing its services to clients. In order to service the clients’ accounts and effect transactions, we may provide clients’ personal information to our firm affiliates or to firms that assist us in servicing client accounts, and have a need for such information to provide the service that the client has requested or authorized, or to maintain and service the client’s account.  The firm may provide clients’ personal information as required by regulatory authorities or law enforcement officials who have jurisdiction over its business activities, or as otherwise required by any applicable law and, to the extent reasonably necessary, to prevent fraud and unauthorized transactions.  We do not otherwise provide information about clients to outside firms, organizations or individuals except as required or permitted by law. Any party that receives this information will use it only for the services required and as allowed by applicable law or regulation, and is not permitted to share or use this information for any other purpose.

Safeguarding standards encompass all aspects of the Platform that affect security. This includes not just computer security standards but also such areas as physical security and personnel procedures. Examples of important safeguarding standards that the firm may adopt are included in its written supervisory procedures and are available upon request.