AT AOS, INC. (AOS) WE VALUE OUR CUSTOMERS, AND MAINTAINING CUSTOMER TRUST AND CONFIDENCE IS OUR HIGHEST PRIORITY. WHILE IT IS NECESSARY THAT WE OBTAIN ACCURATE AND CURRENT INFORMATION ABOUT OUR CUSTOMERS IN ORDER TO PROVIDE THE HIGHEST LEVEL OF CUSTOMER SERVICE, WE ARE DEDICATED TO PROTECTING THE PRIVACY AND CONFIDENTIALITY OF OUR CUSTOMERS' INFORMATION. Pursuant to Title V of the Gramm-Leach-Bliley Act and United States Securities and Exchange Commission ("SEC") Regulation S-P (17 CFR 248.1-248.30), this document sets forth the Privacy Policy of AOS, Inc. ("AOS") concerning the privacy interests of individual consumers and customers (described below and hereinafter referred to as "customers") of financial services. AOS is an Illinois corporation with its principal office in Chicago, IL. AOS is a securities broker dealer registered with the SEC. Among its other securities-related memberships and associations, AOS is a member of the Financial Industry Regulatory Authority, Inc. ("FINRA").
AOS' principal business is to act as an Broker-dealer in accordance with all laws, rules and regulations applicable to Broker-dealers and the business conducted by securities Broker-dealers. As an Broker-dealer, AOS' principal business is to provide retail brokerage services, pursuant to a written clearing agreement that allocate roles, duties and responsibilities between the clearing or "carrying" firm Penson Financial Services, Inc. ("PFS") or Terra Nova Trading, LLC ("TNT") which on a "fully disclosed" basis, provides certain limited and defined "back office" securities clearing, custodial and processing services and AOS the "introducing" or "correspondent" broker dealer (see, e.g., NYSE Rule 382 and NASD Rule 3230).
AOS in its capacity as an Broker-dealer and PFS or TNT in its capacity as a securities clearing firm receive and/or come into contact with certain nonpublic personal information concerning the current and/or former customers of the "introducing" or "correspondent" broker dealers for which PFS or TNT provides securities clearing services, including but not limited to certain nonpublic personal information related to the securities account(s) that said customers open and/or maintain with said introducing or correspondent broker/dealers. Any and all such nonpublic personal information related to such customers and/or such customers' securities account(s) is hereinafter referred to as "nonpublic personal information". AOS receives and/or comes into contact with the nonpublic personal information only for purposes of conducting its business as described above. For convenience herein, "you" or "you" refers to any and all customer(s) described above.
NO SALE OF YOUR NONPUBLIC PERSONAL INFORMATION:
AOS DOES NOT SELL YOUR NONPUBLIC PERSONAL INFORMATION.
NONPUBLIC PERSONAL INFORMATION COLLECTED: In conducting its business as described above, AOS collects (or may collect), for example, the following types of nonpublic personal information: A. Information from you: (1) information you provide in connection with any securities account, margin loan, debit card any other financial product or service, whether in writing, in person, by telephone, electronically or by any other means, such as your name, address, social security number, tax ID number, assets, income, investment objectives, financial situation and debt; and (2) information AOS obtains (or may obtain) for the purpose of tax reporting to you and to the various agencies to which AOS reports as required by law, including disclosures on various Internal Revenue Service ("IRS") forms that AOS collects for tax reporting purposes. B. Information about your securities and/or other transactions: (1) information AOS collects and relates to account balance, payment history, trading activity and any other transactions which AOS acts in the capacity of an Broker-dealer, (2) information AOS collects as part of servicing your account(s), (3) information AOS collects through an Internet "cookie" (an information collecting device from a web server). C. Information about your transactions with nonaffiliated third parties: (1) information from nonaffiliated third parties pursuant to law, rules, regulations, standard securities industry practice and/or legal process, including information and/or documents received, shared, produced or provided in connection with a subpoena, discovery request or other legal process compelling production; and (2) information from nonaffiliated third parties related to servicing your account. D. Information from a consumer-reporting agency: (1) information from a consumer reporting agency regarding your creditworthiness or credit history or other information with regards to margin lending or other financial transactions; (2) information from other outside sources regarding their employment of, credit to or other relationship with you, or verifying representations made by you, such as your employment history, loan or credit card balances.
NONPUBLIC PERSONAL INFORMATION DISCLOSED TO AFFILIATES AND NONAFFILIATED THIRD PARTIES.
AOS discloses to affiliates and nonaffiliated third parties nonpublic personal information only in connection with AOS providing securities services in the capacity of an Broker-dealer. Such disclosures include, among other things, information related to transactions, settlement, billing, payment, processing, clearing, transferring, reconciling, collection and tax reporting. Such disclosures may be provided to affiliates and nonaffiliated third parties: (i) as required or necessary to carry out fully and properly the securities business conducted by AOS (such as, for example, disclosures to affiliated and nonaffiliated third party service providers supplying to AOS computer related, document processing and delivery, and data maintenance or processing services, and disclosures to nonaffiliated third parties such as securities clearing agencies and entities); (ii) as required by law or legal process; or (iii) with your consent. By allowing us to share information about you and the products and services you obtain from us we are better able to serve your financial needs. We may share the information described under the section captioned "Information We Collect" among our affiliated companies that provide financial services, such as Bridge Advisors, a Registered Investment Advisor wholly owned by Trading Block Holdings, Inc., parent company of AOS, Inc.
FORMER CUSTOMERS
AOS will disclose nonpublic personal information about former customers only as permitted and/or required by law or legal process, or with your consent.
CONFIDENTIALITY AND SECURITY OF NONPUBLIC PERSONAL INFORMATION
AOS is committed to implementing and maintaining commercially reasonable and appropriate measures to maintain your nonpublic personal information in a secure and confidential fashion. AOS' information and security procedures include, but are not limited to, the following features: