PRIVACY STATEMENT

Stage 5 Trading, a division of Global Futures & Forex, Inc. (‘GFF Brokers”) is committed to safeguarding the personal information that you provide us. This Privacy Statement describes how we handle and protect personal information we collect about individuals, such as you, who apply for or receive our products and services. The provisions of this notice apply to former customers as well as our current customers.

Why and How We Collect Personal Information

When you apply for or maintain an account serviced by GFF Brokers, we collect personal information about you for business purposes, such as evaluating your financial needs, processing your requests and transactions, informing you about products and services that may be of interest to you, and providing customer service. The personal information we collect about you includes:

• information you provide to us on applications and other forms, such as your name, address, date of birth, social security number, occupation, assets, income, net worth, previous investment experience, and other confidential information considered necessary by us and your FCM to obtain in order to establish an account;
• information about your transactions with us;
• information we may receive from reporting agencies, such as your credit history and creditworthiness, background information, and other entities not affiliated with GFF Brokers;
• recorded conversations between yourself and GFF Brokers’ representatives; and,
• information you provide to us to verify your identity or your financial condition, such as a current driver’s license or passport, bank statements, or information received from other entities not affiliated with GFF Brokers.

How We Protect Personal Information

We limit access to your personal information to those employees who need to know in order to conduct our business, service your account, and help you accomplish your financial objectives, such as providing you with a range of products and services. Our employees are required to maintain and protect the confidentiality of your personal information and our employees are instructed as to best practice methodologies for processing and maintaining confidential customer information.

We maintain physical, electronic, and procedural safeguards to protect your personal information.

We do not rent or sell your company information, your name or personal information to anyone. However, GFF Brokers reserves the right to disclose personal information when it is necessary to fulfill GFF Brokers’ regulatory requirements, protect GFF Brokers’ intellectual or physical property, collect or report debts owed to GFF Brokers, or exercise any right of law on behalf of GFF Brokers.

Disclosure to Non-Affiliated Third Parties

In order to support the financial products and services we provide to you, we may share the personal information described above with third-parties not affiliated with us, including:

• Companies under contract to perform services for us or on our behalf, such as vendors that provide data processing, computer software maintenance and development, transaction processing and marketing services.
• Compliance, accounting, audit, and legal firms that assist GFF Brokers in complying with regulatory requirements. These companies acting on our behalf have been requested by GFF Brokers to keep your personal information confidential. GFF Brokers obtains assurance that the companies maintain privacy statements of their own, however, GFF Brokers is not responsible for the privacy policies of these entities.
• Companies and regulatory authorities as permitted or required by applicable law. For example, we may disclose personal information to cooperate with regulatory authorities and law enforcement agencies to comply with subpoenas or other official requests, and as necessary to protect our rights or property.

Conversations with GFF Brokers Representatives

The Commodity Futures Trading Commission’s Regulation 1.35 (a) requires firms like GFF Brokers to maintain (and therefore tape record) all oral communications provided or received concerning quotes, solicitations (for orders), bids, offers, instructions, trading and prices that lead to the execution of a transaction in a commodity interest and related cash or forward transaction, whether communicated by telephone, voicemail, mobile device, or other digital or electronic media, for a period of one year. Although GFF Brokers prohibits its representatives from using personal cell phone numbers to conduct business for GFF Brokers, GFF Brokers is required to record such communications regardless of whether it occurred on a firm provided or personal phone.  It is GFF Brokers Policy that no representative is permitted to speak to a customer concerning quotes, solicitations (for orders), bids, offers, instructions, trading and prices that lead to the execution of a transaction in a commodity interest and related cash or forward transaction unless the conversation is done over a device that is recorded using technology provided and maintained by GFF Brokers.

Customers and counterparties must consent to the recording of all oral communications that are subject to recording Rules.   The receipt of this Privacy Policy is your notice that all conversations between you and GFF Brokers’ representatives may be recorded and maintained on file under secure measures as outlined in this notice for a period of one year.  SHOULD YOU OBJECT TO THIS RECORDING POLICY, YOU WILL NEED TO NOTIFY OUR OFFICE WITHIN 10 CALENDAR DAYS OF YOUR UNWILLINGNESS TO BE SUBJECT TO YOUR CONVERSATIONS BEING RECORDED WHILE SPEAKING WITH A GFF BROKER’S REPRESENTATIVE AFTER THIS 10 CALENDAR DAY PERIOD, YOUR SILENCE WILL BE ACCEPTED AS YOUR CONSENT TO THIS POLICY.

Use of Cookies

The website utilizes ‘cookies’ to provide custom content, and to measure visitation patterns and user preferences. Cookies are small text files, downloaded onto your computer or mobile device when you visit certain websites. When you return to these websites — or visit other websites that use the same cookies — the websites recognize these cookies and your browsing device.

Our Sites use the following types of cookies:

1. Strictly Necessary Cookies. These cookies are essential, as they enable you to move around our Sites, and use various features, such as accessing secure areas. Without these cookies, some services cannot be provided. These cookies do not gather information about you for marketing or for remembering where you have been on the Internet. This category of cookie is essential for our Sites to work, thus they cannot be disabled.
2. Performance/Analytics Cookies. These cookies collect information about how you use the Sites. For example, the cookies will collect which pages you go to most often and if you get error messages from certain pages. These cookies do not gather information that identifies you. The information these cookies collect is anonymous and is only used to improve how our Sites work. These cookies are not used to target you with online marketing. Without these cookies we can’t learn how our Sites are performing and make relevant improvements that could better your browsing experience.
3. Functionality Cookies. These cookies allow us to remember choices you make and tailor our Sites to provide enhanced features and content to you. For example, these cookies can be used to remember your user name, password, and preferences, or to display popular content based on your historical interests on the Site. These cookies are not used to target you with online advertisements. While these cookies can be disabled, this may result in less functionality during your use of the Sites.
4. Third-Party Cookies. These are cookies that fall into one of the above categories, but are placed on your browsing device by a third party.  We allow third parties with which we have a separate agreement to use cookies and other technologies to collect information about your use of the Sites, including, for example, when you view or interact with one of their advertisements on the Sites or to collect information about your interests when you view or interact with one of their advertisements. We do not share with these third parties any information that would readily identify you (such as email address); however, such parties have limited access to a small amount of information about your device, which is necessary to serve you advertisements on our Sites and on other sites across the Internet that are tailored to your apparent interests.

You can use the browser with which you are viewing the Sites to enable, disable or delete our (first party) cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access certain areas of the Sites. Also, if you disable cookies other parts of the Sites may not work properly.

While third parties that set cookies on our Sites provide a service to us or functionality, as noted above, you should review the third party’s websites, included those listed in the section above, for more information on how they use cookies or about how to opt-out of their cookie-based collection.

NOTICE TO CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS
(AS PROVIDED BY CALIFORNIA CIVIL CODE SECTION 1798.83)

A CALIFORNIA RESIDENT WHO HAS PROVIDED PERSONAL DATA TO A BUSINESS WITH WHOM HE/SHE HAS ESTABLISHED A BUSINESS RELATIONSHIP FOR PERSONAL, FAMILY, OR HOUSEHOLD PURPOSES (A “CALIFORNIA CUSTOMER”) MAY REQUEST INFORMATION ABOUT WHETHER THE BUSINESS HAS DISCLOSED PERSONAL INFORMATION TO ANY THIRD PARTIES FOR THE THIRD PARTIES’ DIRECT MARKETING PURPOSES. IN GENERAL, IF THE BUSINESS HAS MADE SUCH A DISCLOSURE OF PERSONAL DATA, UPON RECEIPT OF A REQUEST BY A CALIFORNIA CUSTOMER, THE BUSINESS IS REQUIRED TO PROVIDE A LIST OF ALL THIRD PARTIES TO WHOM PERSONAL DATA WAS DISCLOSED IN THE PRECEDING CALENDAR YEAR, AS WELL AS A LIST OF THE CATEGORIES OF PERSONAL DATA THAT WERE DISCLOSED. CALIFORNIA CUSTOMERS MAY REQUEST FURTHER INFORMATION ABOUT OUR COMPLIANCE WITH THIS LAW BY EMAILING CLIENT-SERVICES@S5TRADING.COM. PLEASE NOTE THAT WE ARE REQUIRED TO RESPOND TO ONE REQUEST PER CALIFORNIA CUSTOMER EACH YEAR AND WE ARE NOT REQUIRED TO RESPOND TO REQUESTS MADE BY MEANS OTHER THAN THROUGH THIS EMAIL ADDRESS.

Important Information for California Residents

This section applies only to California residents.  It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information.  For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.

Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

Information.  You can request the following information about how we have collected and used your Personal Information during the past 12 months: the categories of Personal Information that we have collected; the categories of sources from which we collected Personal Information; the business or commercial purpose for collecting and/or selling Personal Information; the categories of third parties with whom we share Personal Information; whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient; or whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.

Access.  You can request a copy of the Personal Information that we have collected about you during the past 12 months.

Deletion.  You can ask us to delete the Personal Information that we have collected from you.

Opt-out of sales.  GFF Brokers does NOT sell any of your Personal Information.  If we were to do so in the future, you will be notified and you will have the opportunity to opt-out.   In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.

Opt-in.  If we know that you are younger than 16 years old, we will ask for your permission (or if you are younger than 13 years old, your parent’s or guardian’s permission) to sell your Personal Information before we do so.

Nondiscrimination.  You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.

How to exercise your rights

You may exercise your California privacy rights described above as follows:

Right to information, access and deletion. You can request to exercise your information, access and deletion rights by writing to client-services@s5trading.com

Right to opt-out of the “sale” of your Personal Information.  We do not sell your Personal Information in the conventional sense (i.e., for money).  However, like many companies, we use services that help deliver interest-based ads to you.  California law classifies our use of these services as a “sale” of your Personal Information to the companies that provide the services. This is because we allow them to collect information from our website users (e.g., online identifiers and browsing activity) so they can help serve ads more likely to interest you. You can request to opt-out out of this “sale” of your personal information here: Do Not Sell My Personal Information.

We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights.  We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. Except as described in this privacy policy, we will not use your personal information for any other purpose unless we describe how such information will be used at the time you disclose it to us or we obtain your permission to do so.

EU Rights – Access, Correction, Deletion

Upon a reasonable request, end users in the European Economic Area may access, obtain a copy of, update, correct, or delete your personal data held by us at any time by contacting us using the information provided in the “Contact Us” section below. In order to comply with these requests, we may ask you to verify your identity. Please note that your rights may be limited in certain cases – for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we are permitted by law or are required to keep pursuant to regulatory requirements.  Permissible changes will be reflected in our databases within a reasonable period of time.

We will retain your information for as long as your account is active or as needed to provide you services. Trading and Personal Identifying Information(PII) is retained by GFF Brokers as a result of regulatory requirements which govern our business. PII is held for at least five years after an account has closed. We will retain and use your personal information as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements.

At any time, end users in the European Economic Area may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law.  Such users also have the right to file a complaint with the appropriate data protection authority.

We consider your privacy a very important matter and appreciate the information you have entrusted to us.

We invite you to visit NFA’s BASIC System at www.nfa.futures.org/basicnet.

Sincerely,

Greg Khojikian, President