This privacy disclosure statement puts in writing the privacy policies that GVC follows. Our policy is based on the recognition that our clients have an expectation that non-public personal information will be kept confidential. We have adopted this Privacy Policy concerning information you have provided to us and information we obtained in providing  services to you.

Information about you is collected in the normal course of business for purposes of providing services to you. This information is not collected for resale. We provide information to unaffiliated third parties that is necessary for us to provide services to you. The information that is collected, the source of the information and the parties to which the information is provided are explained below.

Categories of Non-public Information We Collect In the Normal Course of Business:

1. Information you provide in establishing an account. This is information provided by you on forms used to open and maintain an account with us and our affiliates and otherwise provided by you in using our services. Examples of such information are your name, address, employment, age, assets and investment objectives and experience.
2. Information about your transactions. This includes information obtained from you concerning a transaction that we have done on your behalf. We also have information about assets held for you. If your account was transferred to us, we may have received information from another financial institution. Our Brokerage services are introduced by us to a clearing firm that effects transactions and maintains assets for you. We have access to information about these transactions and assets. We anticipate that the clearing firm will separately provide you with their privacy policies concerning client financial information that is collected or available to them.

Categories of Non-public Information That is Disclosed:

We do not disclose any non-public personal information about our clients or former clients to anyone, except as required or permitted by law.

Examples of such disclosures include:

1. All information about your account may be disclosed to any person that you authorized pursuant to the documentation you have provided us. For example, information about accounts held jointly shall be disclosed to all persons jointly sharing the account.

2. Any information that is compelled by law or legal process to be produced, such as pursuant to a subpoena or an order issued by a court.

3. Information provided with your consent or at your direction, such as disclosure to a non-affiliated mortgage lender with which you are applying for a mortgage loan.
4. Information provided to a financial institution to which your account is transferred.

Information provided by us to non-affiliated third parties that assist us in providing our services to you, such as GVC’s third party securities clearing, custody and trade execution firm (Hilltop Securities, Inc.). 

Parties to Whom We May Disclose Non-public Personal Information

We may disclose both identification and transaction information to affiliated and non-affiliated parties as permitted by law for the following reasons:

1. Non-financial Entities.  Such entities include persons that prepare confirmations, account statements and other account records (e.g., including such persons engaged by GVC’s third party securities clearing, custody and trade execution firm (Hilltop Securities, Inc.) and transfer agents to permit the issuance of security certificates to you.
2. Financial Entities.  Such entities include GVC’s third party securities clearing, custody and trade execution firm (Hilltop Securities, Inc.).