Last Updated: 08/08/2024

Engelman Investment Securities ("Company," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, share, and protect your personal information when you use our services or visit our website. By using our services, you consent to the practices described in this Privacy Policy.

1. Information We Collect

1.1 Personal Information:
We may collect personal information that you provide to us directly, including but not limited to your name, address, email address, phone number, date of birth, identification documents, and financial information.

1.2 Non-Personal Information:
We may collect non-personal information automatically when you use our website or services, such as your IP address, browser type, operating system, referral source, pages visited, and the dates/times of access.

1.3 Cookies and Tracking Technologies:
We use cookies and similar tracking technologies to enhance your experience on our website. Cookies are small data files stored on your device that help us analyze how users interact with our website and services.

2. How We Use Your Information

2.1 We may use your personal information to:

• Provide, manage, and improve our services.
• Verify your identity and conduct due diligence.
• Process transactions and manage your investments.
• Communicate with you about your account, investments, and updates.
• Comply with legal obligations, such as anti-money laundering (AML) regulations.
• Detect and prevent fraud, security breaches, or other illegal activities.
• Customize and improve your experience on our website.
• Provide customer support and respond to inquiries.

2.2 We may use non-personal information for analytical purposes, including to monitor website performance, analyze trends, and optimize user experience.

3. Sharing of Your Information

3.1 Third-Party Service Providers:
We may share your personal information with third-party service providers who perform services on our behalf, such as payment processing, customer support, marketing, or data analysis. These providers are bound by confidentiality obligations and are only authorized to use your information as necessary to provide services to us.

3.2 Legal and Regulatory Compliance:
We may disclose your information to comply with applicable laws, regulations, legal processes, or governmental requests, including to fulfill our obligations under anti-money laundering (AML) and counter-terrorism financing (CTF) laws.

3.3 Business Transfers:
If Engelman Investment Securities is acquired, merged, or reorganized, your personal information may be transferred to the new entity. We will notify you before your personal information is transferred and becomes subject to a different privacy policy.

3.4 With Your Consent:
We may share your personal information with third parties when we have your consent to do so.

4. Data Security

4.1 We implement appropriate technical and organizational measures to protect your personal information from unauthorized access, use, disclosure, or destruction.

4.2 While we strive to protect your personal information, no method of transmission over the Internet or electronic storage is 100% secure. Therefore, we cannot guarantee absolute security.

5. Data Retention

5.1 We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws or regulations.

5.2 When your personal information is no longer required, we will securely delete or anonymize it.

6. Your Rights

6.1 You have the right to:

• Access the personal information we hold about you.
• Request correction or deletion of your personal information.
• Object to or restrict the processing of your personal information.
• Withdraw your consent to the processing of your personal information, where consent is the basis for processing.
• Lodge a complaint with a supervisory authority if you believe your rights have been violated.

6.2 To exercise any of these rights, please contact us using the information provided in the "Contact Us" section below.

7. International Data Transfers

7.1 Your personal information may be transferred to and processed in countries outside of your country of residence. These countries may have different data protection laws that may not be as protective as those in your jurisdiction.

7.2 We will take appropriate measures to ensure that your personal information is protected in accordance with this Privacy Policy, including by using appropriate safeguards.

8. Cookies and Tracking Technologies

8.1 We use cookies and similar tracking technologies to improve your experience on our website, analyze usage patterns, and customize content. By using our website, you consent to our use of cookies.

8.2 You can manage your cookie preferences through your browser settings. However, disabling cookies may affect the functionality of our website.

9. Changes to This Privacy Policy

9.1 We may update this Privacy Policy from time to time. Any changes will be posted on our website with an updated "Last Updated" date.

9.2 Your continued use of our services after any changes to this Privacy Policy constitutes your acceptance of the revised terms.