How and why we obtain personal information

Investro takes great care to protect personal information about you and when we use it, we do so with respect for your privacy. We may use personal information about you to service, maintain, and protect your account; process transactions in your account; respond to inquiries from you or your representative; develop, offer, and deliver products and services; or to fulfill legal and regulatory requirements. Investro may collect public and non-public personal information about you from any of the following sources:

    You or your representative on applications or forms (for example, name, address, Social Security number, birth date, assets and income)

    You or your employer or plan sponsor if Investro provides them with recordkeeping and/or benefits advisory services (for example, payroll, human resources, or benefits information)

    Transactional activity in your account (for example, trading history and balances)

    Other interactions with Investro (for example, discussions with our customer service staff, information you enter into our websites, or when you enroll in our authentication services)

    Information from consumer reporting agencies (for example, to assess your creditworthiness for margin products)

    Information from other third-party data services (for example, to verify your identity and to better understand your product and service needs)

    You or your representative regarding your preferences (for example, your choice of electronic statement delivery, or the screen layout you specify if you use our Internet sites)

    Other sources with your consent or with the consent of your representative (for example, from other institutions if you transfer positions into Investro)

Please note that information by which you cannot be identified (for example, anonymous or aggregated information) is not considered personal information and therefore is not subject to this privacy policy.


How we protect information about you

Investro considers the protection of personal information to be a foundation of customer trust and a sound business practice. We employ physical, electronic and procedural controls and we regularly adapt these controls to respond to changing requirements and advances in technology.

At Investro, we restrict access to personal information to those who require it to develop, support, offer and deliver products and services to you.


How we share information about you with third parties

Investro does not share personal information about our customers with unaffiliated third parties for use in marketing their products and services. We may share personal information with the following entities:

    Unaffiliated service providers (for example, printing and mailing companies, securities clearinghouses, marketing service providers, and other entities who may provide services at Investro direction)

    Government agencies, other regulatory bodies and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions)

    Other third-parties, with your consent or as directed by your representative (for example, if you use Investro as a financial reference in applying for credit with another institution or if you use an external aggregation website or service that you have provided permission to access your Investro financial account on your behalf)

    Other organizations as permitted or required by law (for example for fraud prevention or to respond to a subpoena)

Our service providers are obligated to keep the personal information we share with them confidential and use it only to provide services specified by Investro.

Based on the nature of your relationship with Investro, we may exchange information with other third parties as described below:

    If Investro provides workplace services to your employer or plan sponsor, such as payroll, human resources or benefits advisory and/or recordkeeping services, Investro may exchange any information received in connection with such services with your employer or plan sponsor or others they may authorize.

    If you conduct business with Investro through your investment professional, we may exchange information we collect with your investment professional or with others they may authorize.

    If you transact business through Investro 's life insurance companies, we may validate and obtain information about you from an insurance support organization. The insurance support organization may further share your information with other insurers, as permitted by law. We may also share medical information about you to learn if you qualify for coverage, to process claims, to prevent fraud, or otherwise at your direction, as permitted by law.


How we share information about you within Investro

We may share personal information about you with various Investro corporate affiliates including internal service providers which perform, for example, printing, mailing, and data processing services.

Additionally, if you interact with Investro directly as an individual investor (including joint account holders) or if Investro provides services to your employer or plan sponsor, we may exchange certain information about you with Investro financial services affiliates, such as our brokerage and insurance companies, for their use in marketing products and services as allowed by law.

Information collected from investment professionals' customers is not shared with Investro affiliates for marketing purposes, except with your consent and as allowed by law.