It is the policy of Cowen Prime Services LLC (“Cowen Prime Services”) to protect the privacy of our customers who obtain or seek to obtain financial products or services. We do this by protecting the security and confidentiality of your nonpublic personal information.
We restrict access to nonpublic personal information about you to our employees who need to know the information to provide products or services to you. We maintain physical, electronic, and procedural standards that comply with federal standards to guard your nonpublic personal information.
CATEGORIES OF INFORMATION WE COLLECT
We collect nonpublic information about you from the following sources:
• Information we receive from you on applications or other forms;
• Information about your transactions with us, our affiliates, or others; and
• Information we receive from consumer reporting agencies.
CATEGORIES OF INFORMATION WE DISCLOSE TO NONAFFILIATED THIRD PARTIES
• We may disclose your company name, address, and account number to a nonaffiliated third party to execute, process, and confirm your transactions with us or in marketing our products through a joint marketing arrangement.
• We may also disclose nonpublic personal information about you to a nonaffiliated third party to protect the confidentiality or security of our records pertaining to your company
• We may be required to disclose nonpublic personal information concerning you to a law enforcement agency, federal or state regulatory agency, or self-regulatory organization, or if required to do so by a court order, judicial subpoena, or regulatory inquiry
We do not disclose any other nonpublic personal information about you to nonaffiliated third parties
CATEGORIES OF INFORMATION WE DISCLOSE TO OUR AFFILIATED COMPANIES
• We may disclose your name, address, account number, and financial information to affiliated companies for risk management or risk control purposes, or if necessary to resolve a dispute or inquiry or enforce a contractual undertaking by you
• We do disclose your name, address, account number, and account balance to our clearing firms, National Financial Services LLC, Pershing LLC, Merrill Lynch, Pierce, Fenner and Smith Incorporated, Merrill Lynch Professional Clearing Corp., J. P. Morgan Clearing Corp., INTL FCStone, Inc. and ADM Investor Services, Inc. to execute, process, and confirm your transactions with us
• We may disclose to our affiliated companies information solely as to your transactions with us or our business experience with you
INFORMATION ABOUT FORMER CUSTOMERS
We do not disclose nonpublic information about former customers to anyone unless required to do so by a court order, judicial subpoena, or regulatory inquiry.