FACTS: WHAT DOES INTERCHANGE CLEARING LLC (“INTERCHANGE”) DO WITH YOUR PERSONAL INFORMATION?
Who?
As a clearing firm, Interchange provides clearing services to your Introducing Financial Institution including Introducing Broker Dealers and Registered Investment Companies pursuant to a Fully Disclosed Clearing Agreement. Examples of these clearing services include, but are not limited to trade execution, trade reporting, and other back-office operations. The nature of these services requires Interchange to receive and retain nonpublic personal information.
Why?
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Interchange is committed to protecting the privacy of all nonpublic personal information that it receives. Federal law also requires us to tell you how we collect, share, and protect your personal information.
Please read this notice carefully to understand what we do.
What?
- We collect your personal information from your introducing broker dealer in order to provide the services necessary to maintain your account. The types of personal information we collect and share may include, but are not limited to:
- Personal information, such as Social Security number and date of birth
- Financial information, such as account balances, positions and transactions, income, and net worth
- Contact information, such as phone numbers and email addresses
- Demographic information, such as gender, education, and occupation
- Derived data, device info, IP address (unique device IDs or browser type)
| Reasons We Can Share Your Personal Information | Does Interchange Share? | Can You Limit This Sharing? |
|---|---|---|
| For our everyday business purposes: Such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus | Yes | No |
| For our non-affiliates’ everyday business purposes: Interchange may enter into contracts with certain nonaffiliated third party service providers in connection with the services they provide to Interchange. We have legal agreements with these companies that require them to protect your personal information and to comply with the law. | Yes | No |
How?
All financial companies need to share customers’ personal information to run their everyday businesses. In the section below, we list the reasons financial companies like Interchange can share customers’ personal information, whether Interchange generally shares, and whether you can limit this sharing. If you are no longer a customer of one of our introducing broker-dealer clients, we may nevertheless continue to share your information as described in this notice.
Who is providing this notice?
Interchange Clearing LLC
How Does Interchange Clearing LLC Protect My Personal Information?
To protect your personal information from unauthorized access and use, Interchange maintains physical, electronic, and procedural safeguards in accordance with industry and legal standards.
How Does Interchange Clearing LLC Collect My Personal Information?
Interchange Clearing LLC may collect information:
- Directly from you or your introducing broker-dealer via API, portal, applications or other forms;
- We collect and process PI through the use of our technology and other services including, without limitation, the Interchange API Service, the white-labeled Interchange Portal we provide to our Clients;
- From consumer and credit reporting agencies;
- Received from other sources with your consent or the consent of your introducing broker-dealer.
Why Can’t I Limit All Sharing?
Federal law gives you the right to limit only:
- Sharing for affiliates’ everyday business purposes – information about your creditworthiness
- Affiliates from using your information to market to you
- Sharing for non-affiliates to market to you State laws and individual companies may give you additional rights to limit sharing
What are your data protection rights?
Interchange would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
The Right to Access
You have the right to request Interchange for copies of your personal data. We may charge you a small fee for this service.
The Right to Rectification
You have the right to request that Interchange correct any information you believe is inaccurate. You also have the right to request Interchange to complete information you believe is incomplete.
The Right to Erasure
You have the right to request that Interchange erase your personal data, under certain conditions.
The Right to Restrict Processing
You have the right to request that Interchange restrict the processing of your personal data, under certain conditions.
The Right to Object to Processing
You have the right to object to Interchange’s processing of your personal data, under certain conditions.
The Right to Data Portability
You have the right to request that Interchange transfer the data that we have collected to another organization, or directly to you, under certain conditions.
California Residents
The California Consumer Privacy Act of 2018 (“CCPA”) imposes certain obligations on businesses and allows a resident to make certain requests to a business regarding the personal information the business maintains. However, the CCPA does not apply to all business or personal information. Since we are a financial institution subject to GLBA, and the type of personal information we collect is covered by a CCPA exemption, the CCPPA does not apply to us.