Online Privacy and Security

First Clearing, LLC Online Privacy Policy

This policy is effective as of June 20, 2011
In the information age, First Clearing, LLC’s commitment to protect your information and your privacy extends to your use of our online services offered through your brokerage firm. While our privacy policies are the same whether you are online or not, we have extra measures in place to protect your privacy when you access our online services.

Information for Visitors

  • If you do not access your account online with First Clearing, LLC, we do not collect, capture, or retain personally identifiable information when you are just browsing or viewing Access Online demos unless otherwise disclosed to you.

Information for Registered Users

  • When you sign up for online account access (Access Online), our Web site or Support Center will request information, such as your email address or your account number. This information allows you to perform certain tasks (for example, correspond with us or review your accounts), and it allows us to provide the information you requested. In these cases, we collect only the information necessary to interact with you. We also gather data to track Web site usage, such as number of hits, pages visited, and the length of user sessions in order to evaluate the usefulness of our sites.

About Cookies

  • Cookies are pieces of data assigned by a Web server to the browser on your PC. Cookies help Web sites track your preferences and recognize return visitors. So, when you return to a Web site you've visited before, your browser gives this data back to the server. Contrary to reports about cookies, cookies do not contain viruses. We do not embed your Social Security number, account number(s) or password in our cookies.
  • First Clearing, LLC uses cookies to make your online experience with us and certain linked Web sites richer and more personalized based on the products and services you have with us. Also, cookies help us confirm your identity and help us keep your transactions with us secure.
  • We also use cookies for various purposes, such as maintaining continuity during an online session, gathering data about the use of our site or monitoring our online promotions;
  • We recommend that you complete your online transactions and sign off before surfing to other sites or turning off your PC. We also suggest that you do not surf to other sites during your online session.

You Cannot Use Access Online Without Cookies

  • You can set your browser to reject cookies. However, if you choose to reject cookies, you cannot access your accounts online with First Clearing, LLC. If your browser rejects cookies, you may not be able to sign on to your favorite sites or use the features you like most within those sites.
  • The latest versions of Microsoft and Netscape's browsers allow you to reject cookies automatically. With this feature, it may not be necessary for you to set your browser to reject cookies. Earlier versions of Microsoft or Netscape's browsers may require you to set your browser to reject cookies when you are just browsing and accept cookies when you want to conduct online transactions. We encourage you to read the privacy policies of the Web sites you visit before you accept cookies from them.

About Online Marketing

  • When browsing the Internet, you may see a banner ad for First Clearing Correspondent Services on non-First Clearing, LLC Web sites. We use third-party ad serving companies to serve our ad banners to sites on which we've paid to advertise. If you click on one of our ads, you go to a First Clearing site offering clearing service related products or services intended for Broker Dealer use only.
  • Sometimes, these ads may contain small graphics with "tags" in them. These tags tell us how many people respond to our ads. They do not identify you personally. Instead, these tags are used only to measure the effectiveness of our ads placed on non-First Clearing sites. The companies that distribute our ads are prohibited by contract from using information other than for the agreed upon purposes — to help us market our products and services and to measure response rates.

About Privacy and Security During Your Online Sessions

  • The information you provide to us online is protected by Secure Socket Layer (SSL) technology. SSL is the leading security protocol for data transfer on the Internet. This technology scrambles your account information as it moves between your PC's browser and First Clearing, LCC’s computer systems. When information is scrambled or encrypted in this way, it becomes nearly impossible for anyone other than First Clearing to read it. This secure session helps protect the safety and confidentiality of your information when you are using Access Online.

About Our Use of Email Communications For Servicing Your Account

  • Email to First Clearing -- When you send us an email, we use your email address to reply, and for a limited time we may store your email address, your message, and our response for quality assurance purposes. We may also do this to meet legal and regulatory requirements.
  • Handling suspicious email -- Should you receive a suspicious email that appears to be from First Clearing, please let us know by emailing us at reportphish@wellsfargo.com. You may also wish to contact your Internet Service Provider for support in blocking emails or subscribing to a spam filter they may offer.
  • Alerts requested by you – You do have the ability to set up email alerts related to your Access Online accounts for market notifications, statements or shareholder communications.  An email notification will be sent to the email address you selected on the Delivery Preferences page. The email notification will specify the document type and indicate the account(s) for which the document is available online. It is your responsibility to provide and maintain an accurate email address to which notifications can be sent. You can update/change your email address on Access Online by selecting "Change Email Address" under the My Profile section of the Customer Service tab.

There are many reasons an email could fail to be received or delivered. If this occurs, a secure message will be generated and sent to your Message Center inbox. To view this secure message, select "Read Secure Message" under the Customer Service tab. The secure message will notify you of the availability of your online document, the attempted email delivery, and request that you make any necessary change to your email address that is on file. The secure message is typically sent the day after an email fails.

Use of Your IP Address

  • When you log in to Access Online, you pass through a "firewall" we use for security purposes. As you pass through it, we may identify the Internet Protocol (IP) address associated with the device you are using, such as a personal computer or handheld device. The IP address does not identify you personally, but it may allow us to identify the device you're using. In certain instances, we may also obtain other information to allow us to better identify you as an Access Online client. We may retain this information in case we ever need it for reasons related to the protection of client information and/or security.

Managing Your Information Online

  • If you are an Access Online client, you may update some of your personal information quickly and easily online, including your access information (i.e., change or reset your security questions) and email addresses for alert services. Navigate to Customer Service > My Profile for more information.

Working With Other Companies

  • We work with a number of other companies to ensure that we are providing the value and service you expect from a leader in financial and Internet services, including:
    • Service providers on the Internet -- Occasionally you will notice on our Web sites that services are "powered by" or "provided by" content providers or technology service partners. We contract with these specialists to help us serve you better. We're highly selective in choosing these companies, and they are only allowed to use client information for the purpose of providing the services we've contracted with them to provide.

    • Co-branded and alliance relationships -- First Clearing has established relationships with other parties on the Internet to bring you the benefit of products and services we may not offer. We offer you access to these other companies either through the use of hyperlinks to their sites from our site or by offering "co-branded" sites in which both First Clearing and the other company share the same URL, domain name or pages within a domain name on the Internet and the names or logos of both companies are displayed. Generally, we do not own the co-branded sites and alliance companies and therefore do not control how those companies use any information you supply them. It's important that you review their privacy policies to understand how they manage any information you supply them. However, if you are providing information to First Clearing, we will always adhere to our Privacy Statement.

About Aggregation Services

  • Account aggregation is a service that allows you to gather information from many Web sites and present that information in a consolidated format on one site. The information gathered can range from public information to more personal account information, such as credit card and banking data. For aggregation to work, you may have to provide the aggregation provider with personal account information, such as your online usernames and passwords (access information), that you would normally use yourself to access your data.

  • First Clearing and its vendors will actively work to provide accurate information through aggregation. However due to the nature of the service, First Clearing and its vendors are dependent upon the quality and timeliness of aggregated information from the original source of the information. Thus, First Clearing does not recommend using aggregated information as a basis for any financial or investment decisions.

Aggregation Offered Through First Clearing, LLC

  • First Clearing offers aggregation services through service providers, allowing you convenient access to the accounts you have with us as well as information stored at other Web sites with which you hold accounts. You may, for example, consolidate financial, credit card, insurance and news information into one place. The service providers we use to bring you this service will act as your agent when accessing your accounts. As such, we require that they agree to and abide by our corporate security standards, including encryption of your data, to protect client information. To use our aggregation service, you must provide:

    • Information to help us service your account, such as your email address

    • Information to access accounts you have with other institutions or companies, such as the name of the company, account number, user name or passwords

Aggregation Offered by Other Companies
  • There are a number of other companies that currently offer aggregation. While we recognize that you may want to use these services, you should note a potential risk. Providing an aggregator your access information, such as user names and passwords, may result in unauthorized access and use of your confidential account information by the aggregator or a third party if adequate controls are not in place. Therefore, you should ensure that the aggregation service provider has appropriate processes in place to ensure the privacy and security of your information. If you provide information about your First Clearing accounts, including your access information, to an aggregation service provider, we will consider that as you having authorized all transactions initiated by that aggregation site. First Clearing reserves the right to disable aggregation for any aggregation service provider or any account without notice. If you cancel your third party aggregation services, you should also change your password on Access Online.

  • Safeguarding of your login credentials is your responsibility. You agree to keep these numbers and codes confidential to prevent unauthorized access to your accounts and unauthorized use of the services. For security purposes, we recommend that you do not use the same numbers and codes you use for accessing other financial products and services. Visit our Online Access Services Agreement for more information.

Protecting Children's Privacy Online

  • From our Web sites, we do not knowingly collect or use personal information from children under 13 without obtaining verifiable consent from their parents. We are not responsible for the data collection and use practices of nonaffiliated third parties to which our Web sites may link. For more information about the Children's Online Privacy Protection Act (COPPA), visit the FTC Web site at www.ftc.gov.

Links to Non-First Clearing Sites

  • We are not responsible for the information collection practices of the non-First Clearing links you click to from our Web pages. We cannot guarantee how these third parties use cookies or whether they place on your computer cookies that may identify you personally. We urge you to review the privacy policies of each of the linked Web sites you visit — before you provide them with any personally identifiable information.

Policy Changes

  • If it is necessary to make changes to our online privacy policies, we will update the First Clearing Online Privacy Policy with the changes and new effective date.

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