Bellwether Capital Management, LP Member of National Futures Association

Privacy Policy

Bellwether Capital Management, LP: Privacy Policies

  1. PROTECTING YOUR CONFIDENTIAL INFORMATION:

We, at Bellwether Capital Management, LP (“Bellwether Capital”) value our relationship with each of our customers, and we appreciate the trust that you have placed in us. We recognize that you have concerns about the confidential personal information we obtain about you throughout our relationship. Because protecting your confidential information is important to us, we have adopted a privacy policy which governs how the confidential information we obtain about you is used and maintained. We pledge to protect that information and ensure that it remains private. The information in this notice summarizes the categories of personal information that we collect about you, how that information is handled, and how we protect that information.

We do not disclose any non-public personal information about our customers to anyone, except as required or permitted by law. Bellwether Capital does not sell personal information obtained about you to companies that are not associated with Bellwether Capital for the purpose of marketing their products or services to you.

These written Privacy Policies apply to and are initially provided to former clients, current clients and applicants on commencement of relationship with Bellwether Capital and annually thereafter (every 12 months)

  1. PERSONAL INFORMATION:

When you apply for or maintain a live account with Bellwether Capital, 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. Such information may include:

  1. Application information: Information you provide to us on applications and other forms, such as your name, address, birth date, Social Security number, occupation, assets, and income;
  2. Transaction information: Information about your transactions with us and with our affiliates as well as information about our communications with you. Examples include your account balances, trading activity, your inquiries, and our responses;
  3. Verification information: Information necessary to verify your identity, such as a passport or driver’s license. Examples also include background information about you we receive from public records or from other entities not affiliated with Bellwether Capital. The USA PATRIOT Act requires us to collect information and take actions necessary to verify your identity.
  4. CUSTOMER AML NOTICE:

To help the Government fight the funding of terrorism and money laundering activities, Federal Law requires all financial institutions to obtain, verify and record information that identifies each person who open an account What this means to you, when you open an account, we will ask you for:

– Full Name

– Full address

– Date of birth

– A valid Driver License or Government issued identifying documents

  1. ABOUT COOKIES:

Cookies are small files containing information that a Web site uses to track its visitors. Bellwether Capital may set and access Bellwether Capital cookies on your computer, enabling us to learn which advertisements and promotions bring users to our Web site. Bellwether Capital or any of its divisions may use cookies in connection with products and services to track your activities on our Web sites. Such information that we collect and share would be anonymous and not personally identifiable.

  1. SECURITY TECHNOLOGY:

Bellwether Capital uses Secure Socket Layer (SSL) encryption technology in order to protect certain information that you submit. This type of technology protects you from having your information intercepted by anyone other than Bellwether Capital while it is being transmitted to us. We work hard to ensure that our Web sites are secure and that they meet industry standards. We also use other safeguards such as firewalls, authentication systems (e.g., passwords and personal identification numbers), and access control mechanisms to control unauthorized access to systems and data.

  1. SHARING INFORMATION WITH OUR AFFILIATES:

We may share personal information described above with our affiliates for business purposes, such as, but not limited to, servicing customer accounts and informing customers about new products and services, or to aid in the trading activity of the company, its affiliates, or employees, and as permitted by applicable law. Our affiliates may include companies controlled or owned by us as well as companies that have an ownership interest in our company. The information we share with affiliates may include any of the information described above, such as your name, address, trading and account information. Our affiliates maintain the privacy of your information to the same extent Bellwether Capital does in accordance with this Policy.

  1. SHARING INFORMATION WITH THIRD PARTIES:

Bellwether Capital does not disclose your personal information to third parties, except as described in this Policy. As permitted by law, we may disclose some or all of the information described above with entities that are not affiliated with Bellwether Capital for the purpose of servicing your accounts, improving our services, providing products and services you’ve requested from Bellwether Capital, and informing you about products or services available from Bellwether Capital that may be of interest to you. Such companies may include:

a- Companies that are the source or origin of financial services offered by Bellwether Capital, such as banks, securities broker-dealers, mutual fund companies and insurance companies.

b- Non-financial companies, such as companies that perform services on our behalf, (e.g., check printers, quote vendors, companies that prepare account statements for us, companies that assist us in communicating or marketing our services.)

c- Others, such as independent contractors or technical system consultants who program our software, government agencies and regulators, consumer reporting agencies, and other outside entities as permitted or required by applicable laws.

  1. REGULATORY DISCLOSURE:

Under limited circumstances, Bellwether Capital may disclose your personal information to third parties as permitted by, or to comply with, applicable laws and regulations. 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. 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.

  1. OPT OUT:

You are not required to supply any of the personal information that we may request; however, failure to do so may result in our being unable to open or maintain your account or to provide services to you. While we make every effort to ensure that all information we hold about you is accurate, complete, and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.

If you do not wish to have your personal information disclosed to our affiliates or other third parties as described in this Policy, please contact us via e-mail to: compliance@bellwether.capital or send your request to:

Bellwether Capital Management, LP

Attention: Compliance Officer

75 Maiden Lane,

New York, NY 10038

Please be advised, that if we receive such instruction we will not be able to service your account and must close any open and funded accounts you have.