Your privacy is important to us, and we take our responsibility to protect our customers’ personal information very seriously. This Privacy Notice is provided by Castle Brokerage LLC (“Castle Brokerage” or “we” or “us”) regarding the accounts customers open with futures commission merchants (“FCM”), designated contract markets (“DCM”), or other entities as applicable (each, a “Referral Recipient”) pursuant to referrals of such customers by Castle Brokerage (such referrals, the “services”). This Privacy Notice sets forth the policies of Castle Brokerage regarding the collection, use, sharing, disclosure, and storage of personal information (as defined below) relating to services provided by us in the United States to current, prospective, and former customers (“customer” or “you”).
Personal Information
“Personal Information” means any information relating to an identifiable individual who can be identified from such information, either alone or in combination with other information, including “nonpublic personal information” as defined under the Gramm-Leach-Bliley Act (“GLBA”). During the course of our relationship with you, we collect Personal Information from and about you. The categories of Personal Information that we collect include: name; email address; residential address; telephone number or other contact details; date of birth; nationality; Social Security number; driver’s license or other government-issued identification number; passport details and number; employment details; account balance; income; credit history; information regarding trading history and investment activities; net worth information related to trading activity and assets; and certain sensitive categories of Personal Information (as such term is defined under applicable data protection laws).
How We Collect Your Personal Information
We collect Personal Information from (i) applications, documents, and forms that you provide directly to us, or that we receive from another person on your behalf, for identify verification and other purposes; (ii) written or oral communications from or with you directly; and (iii) other sources, which may include our affiliates, consumer reporting agencies, regulatory, tax, or governmental authorities or entities.
How We Disclose Your Personal Information
We may disclose your Personal Information to our affiliates (e.g., financial and non-financial companies under common ownership or control) and to nonaffiliated third parties (e.g., financial and non-financial companies not related to or under common ownership or control with or by us) in the following circumstances: (i) to a Referral Recipient; (ii) to third parties that maintain, process, or service customer accounts or act as an intermediary in connection with the making, management, or disposition of any transaction on or through a Referral Recipient; (iii) as otherwise necessary to administer or effectuate our services; and (iv) as permitted by law. We may share your Personal Information with our affiliates for direct marketing purposes, such as offers of products and services to you. If you would like to opt out or limit the sharing of your Personal Information, please contact us through one of the methods listed at the bottom of this Privacy Notice. We do not disclose your Personal Information to non-affiliated third parties for marketing purposes.
We may also disclose your Personal Information to other non-affiliated entities (e.g. certain agents and service providers, including but not limited to, accountants, auditors, and legal counsel) in connection with the administration and execution of the services we provide for you and your account, including: responding to customer inquiries, preparing tax forms or disclosures, maintaining the security of our information technology systems, and fulfilling our compliance obligations with respect to securities or anti-money laundering laws or regulations. We may further disclose your Personal Information pursuant to valid requests from law enforcement or governmental authorities to comply with a notice, complaint, demand, subpoena, litigation, investigation, or in response to a judicial or administrative proceeding.
How We Protect Your Personal Information
We maintain reasonable physical, technical, organizational, and administrative security safeguards to protect your Personal Information. We protect the security and confidentiality of Personal Information in compliance with applicable law and our internal information security policies and procedures. In addition, we restrict access to your Personal Information solely to our employees, agents, registered representatives, and service providers who have a need to know such information and when there is a valid business reason to do so, such as to administer or offer our services. Third parties with whom we share Personal Information are contractually or legally required to maintain the confidentiality of your Personal Information. When we disclose Personal Information to third parties, such as Referral Recipients, we utilize certain physical, technical, organizational and administrative security safeguards and measures to protect the security of Personal Information. Castle provides customers with an initial and annual privacy notice as required under CFTC Part 160.
Retention of Personal Information
We will not retain your Personal Information for longer than is necessary for the purpose for which it was collected, subject to our compliance with applicable laws. Your Personal Information will be retained while we are providing you with our services and for a minimum of five years after we have ceased providing the relevant services to you pursuant to CFTC Regulation 1.31.
Correction and Deletion of Personal Information
Upon written request, we will make available for your review any file that includes your Personal Information, subject to compliance with applicable laws. If you notify us that any Personal Information we hold is incorrect, we will review it and make a determination regarding whether the Personal Information should be corrected.
Notice to California Residents
California residents have privacy rights regarding their Personal Information under the California Consumer Privacy Act (“CCPA”). Please note that the CCPA also includes certain exemptions under federal law that apply to our compliance obligations with respect to Personal Information. For example, the Personal Information that we collect as part of our prospective, former, or current customer relationships may be subject to the protection afforded by the GLBA and exempt from the requirements of the CCPA.
Contact Information
We reserve the right to amend this Privacy Notice at any time. If you have any questions regarding this Privacy Notice or would like to submit a request for correction or deletion of Personal Information, please email us at contact@castle.tech or by phone +1 (650) 862-8473.