VTS’s principal business is to act as a fully disclosed securities Broker Dealer (BD) in accordance with all laws, rules and regulations applicable to a securities BD and the business conducted by a securities BD. As a BD VTS’s principal business is to facilitate execution of orders received both on a solicited and unsolicited basis for both its institutional and non-institutional clients. VTS has a clearing agreement with Apex Clearing, Incorporated, who provides certain limited and defined “back office” securities clearing, custodial and processing services.
In its capacity as a securities BD, VTS receives and/or comes into contact with certain nonpublic personal information concerning its current and/or former customers, including but not limited to certain non public personal information related to the securities account(s) that said customers open and/or maintain with VTS. Any and all such nonpublic personal information related to such customers and/or such customers’ securities account(s) is hereinafter referred to as “nonpublic personal information”. VTS receives and/or comes into contact with the nonpublic personal information only for purposes of conducting its business as described above. For convenience herein, “you” or “your” refers to any and all customer(s) described above.
NO SALE OF YOUR NONPUBLIC PERSONAL INFORMATION. VTS DOES NOT SELL YOUR NONPUBLIC PERSONAL INFORMATION. NONPUBLIC PERSONAL INFORMATION COLLECTED.
In conducting its business as described above, VTS collects (or may collect), for example, the following types of nonpublic personal information:
A. Information about you: (1) information you provide in connection with securities account, margin loan, debit card or any other financial product or service, whether in writing, in person, by telephone, electronically or by any other means, such as your name, address, social security number, tax ID number, assets, income, investment objectives, financial situation and debt; and (2) information VTS obtains (or may obtain) for the purpose of tax reporting to you and to various agencies to which VTS reports as required by law, including disclosures on various Internal Revenue Service (IRS) forms that VTS and/or its clearing firm collects for tax reporting purposes.
Information about your securities and/or other transactions: (1) information VTS collects and relates to account balance, payment history, trading activity and any other transactions concerning which VTS provides brokerage services; (2) information VTS collects as part of servicing your account(s), as a BD; and (3) information VTS may collects through an internet “cookie” (an information collecting device from a web server).
A. Information about your transactions with nonaffiliated third parties: (1) information from nonaffiliated third parties pursuant to law, rules, regulations, standard securities industry practice and/or legal process, including information and/or documents received, shared, produced or provided in connection with a subpoena, discovery request or other legal process compelling production; and (2) information from non affiliated third parties related to servicing your account for purposes of providing securities BD services.
B. Information from a consumer reporting agency: (1) information from a consumer reporting agency regarding your creditworthiness or credit history or other information with regards to margin lending or other financial transactions; (2) information about the fact that you are a customer of VTS; and (3) information from other outside sources regarding their employment of, credit to or other relationship with you, or verifying representations made by you, such as your employment history, loan or credit card balances.
NONPUBLIC PERSONAL INFORMATION DISCLOSED TO AFFILIATES AND NONAFFILIATED THIRD PARTIES.
VTS discloses to its affiliates and nonaffiliated third parties nonpublic personal information only in connection with VTS providing securities BD services. Such disclosures include, among other things, information related to transactions, settlement, billing and payment. Such disclosures may be provided to affiliates and nonaffiliated third parties: (i) as required or necessary to carry out fully and properly the securities business of VTS (such as, for example, disclosures to affiliated and nonaffiliated third party service providers supplying to VTS computer related, document processing and delivery, and data maintenance or processing services, and disclosures to nonaffiliated third parties such as clearing agencies and entities); (ii) as required by law or legal process; or (iii) with your consent.
VTS will disclose nonpublic personal information about the former customers of VTS only as permitted and/or required by law or legal process, or with your consent.
CONFIDENTIALITY AND SECURITY OF NONPUBLIC PERSONAL INFORMATION
VTS is committed to implementing and maintaining commercially reasonable and appropriate measures to maintain your nonpublic personal information in a secure and confidential fashion. VTS’s information and security procedures include. But are not limited to the following features;
Access controls on customer information systems, including controls to authenticate and permit access only to authorized individuals and controls to prevent VTS employees from providing nonpublic information to unauthorized individuals who may seek to obtain this information through fraudulent means.
Physical access restrictions at locations containing nonpublic personal information
Stringent pre-employment screening, including fingerprinting, and segregation of duties for VTS employees with responsibilities for or access to nonpublic information.
VTS regularly reviews, revises and updates its information security program to account for changes in technology.
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