PRIVACY Policy

OUR COMMITMENT TO PRIVACY

IF Direct LLC and its affiliates (“IF Direct LLC”) are committed to maintaining the confidentiality, integrity, and security of personal information about our current and prospective customers. In this policy personal information means “personally identifiable information”.

Please note that certain details of this policy may depend on whether you deal with us through an investment professional, directly as an individual investor, or whether IF Direct LLC provides services to your employer or plan sponsor.

IF DIRECT LLC INVESTMENTS PRIVACY POLICY

How and why we obtain personal information

IF Direct LLC takes great care to protect personal information about you and when we use it, we do so with respect for your privacy. We may use personal information about you to service, maintain, and protect your account; process transactions in your account; respond to inquiries from you or your representative; develop, offer, and deliver products and services; or to fulfill legal and regulatory requirements. IF Direct LLC may collect public and non-public personal information about you from any of the following sources:

• You or your representative on applications or forms (for example, name, address, Social Security number, birth date, assets and income)
• You or your employer or plan sponsor if IF Direct LLC provides them with recordkeeping and/or benefits advisory services (for example, payroll, human resources, or benefits information)
• Transactional activity in your account (for example, trading history and balances)
• Other interactions with IF Direct LLC (for example, discussions with our customer service staff, information you enter into our websites, or when you enroll in our authentication services)
• Information from consumer reporting agencies (for example, to assess your creditworthiness for margin products)
• Information from other third-party data services (for example, to verify your identity and to better understand your product and service needs)
• You or your representative regarding your preferences (for example, your choice of electronic statement delivery, or the screen layout you specify if you use our Internet sites)
• Other sources with your consent or with the consent of your representative (for example, from other institutions if you transfer positions into IF Direct LLC)

How we protect information about you

IF Direct LLC considers the protection of personal information to be a foundation of customer trust and a sound business practice. We employ physical, electronic and procedural controls and we regularly adapt these controls to respond to changing requirements and advances in technology.

At IF Direct LLC, we restrict access of personal information to those who require it to develop, support, offer and deliver products and services to you.

How we share information about you with third parties

IF Direct LLC does not share personal information about our customers with unaffiliated third parties for use in marketing their products and services. We may share personal information with the following entities:

• Unaffiliated service providers (for example, printing and mailing companies, securities clearinghouses, marketing service providers, and other entities who may provide services at IF Direct LLC’s direction)
• Government agencies, other regulatory bodies and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions)
• Other third-parties, with your consent or as directed by your representative (for example, if you use IF Direct LLC as a financial reference in applying for credit with another institution or if you use an external aggregation website or service that you have provided permission to access your IF Direct LLC financial account on your behalf)
• Other organizations as permitted or required by law (for example for fraud prevention or to respond to a subpoena)

Our service providers are obligated to keep the personal information we share with them confidential and use it only to provide services specified by IF Direct LLC.

Based on the nature of your relationship with IF Direct LLC, we may exchange information with other third parties as described below:

• If IF Direct LLC provides workplace services to your employer or plan sponsor, such as payroll, human resources or benefits advisory and/or recordkeeping services, IF Direct LLC may exchange any information received in connection with such services with your employer or plan sponsor or others they may authorize.
• If you conduct business with IF Direct LLC through your investment professional, we may exchange information we collect with your investment professional or with others they may authorize.
• If you transact business through IF Direct LLC’s life insurance companies, we may validate and obtain information about you from an insurance support organization. The insurance support organization may further share your information with other insurers, as permitted by law. We may also share medical information about you to learn if you qualify for coverage, to process claims, to prevent fraud, or otherwise at your direction, as permitted by law.

How we share information about you within IF Direct LLC

We may share personal information about you with various IF Direct LLC corporate affiliates including internal service providers which perform, for example, printing, mailing, and data processing services.

Additionally, if you interact with IF Direct LLC directly as an individual investor (including joint account holders) or if IF Direct LLC provides services to your employer or plan sponsor, we may exchange certain information about you with IF Direct LLC financial services affiliates, such as our brokerage and insurance companies, for their use in marketing products and services as allowed by law.

Information collected from investment professionals’ customers is not shared with IF Direct LLC affiliates for marketing purposes, except with your consent and as allowed by law.

Your digital privacy

Privacy, security, and service in IF Direct LLC’s online operations are just as critical as in the rest of our business. We use firewall barriers, encryption techniques, and authentication procedures, among other controls, to maintain the security of your online session and to protect systems from unauthorized access.

Additional information

If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current customers.

IF Direct LLC offers several options for accessing and, if necessary, correcting your account information. You can review your information using your statements. You may also write or call us with your request for information. Specific Internet addresses, mailing addresses and telephone numbers are listed on your statements and other correspondence.

You can click here for our clearing firm – Hilltop Securities, Inc. Privacy Policy.

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This Privacy Notice for California residents (“Notice”) supplements The IF Direct LLC’s Privacy Notice and applies to all individuals who reside in California (“consumers,” “you,” or “your”). The IF Direct LLC has adopted this Notice for all of its subsidiaries and related entities (collectively, “IF Direct LLC,” “we,” “our,” or “us”) whose activities fall within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).

For the purpose of this Notice, personal information does not include information that is exempted from the CCPA, such as personal information covered by other privacy laws such as the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, or the California Financial Information Privacy Act. Depending on whether you have or had a business relationship with us, the CCPA may not apply to you or all of your personal information.

Personal Information We Collect

We have collected the following categories of personal information (collected and used solely within the context of California residents’ roles, as listed here) from consumers (including consumers who are job applicants to or employees, owners, directors, officers, or contractors of IF Direct LLC) within the last 12 months:

• Identifiers such as real name, postal address, email address, telephone number, online identifiers, driver’s license number, Social Security number, passport number, government issued identification, or other similar identifiers;
• Protected classification characteristics under California or federal law such as age and gender;
• Financial and commercial information such as investment background and experience, as well as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
• Internet or other network activity information such as information regarding your interaction with our websites, applications, and advertisements;
• Professional or employment related information, which includes information necessary to conduct background screenings; and
• Inferences drawn from such information.

Sources of Personal Information

We collect the categories of personal information listed above from the following categories of sources:

• Directly from you or those acting on your behalf. For example, from forms you complete online or at events, when you request information about or obtain our products and services, and information that is automatically collected from internet or other network activity regarding your interaction with our websites, applications, and advertisements; and
• Government entities from which public records are maintained and other publicly available sources and unaffiliated service providers, including data resellers.

How We Use Your Information

We have used or disclosed the personal information collected for one or more of the following business purposes within the last 12 months (excluding uses or disclosures we may be prohibited from reporting under applicable law):

• To conduct our business, including providing our products and services, and, where necessary, in order to assist us in verifying your identity, and to provide support, personalize, and develop our products and services;
• To fulfill and respond to your inquiries and requests, including providing you with support, investigating and addressing your concerns, monitoring and improving our responses, and to otherwise carry out the purposes for which you provided the information;
• For our marketing and promotional event services. We do not share your personal information for joint marketing with other financial companies or for non-affiliates to market to you;
• To personalize your experience with our business and to deliver content, product, and service offerings relevant to your interests, including targeted offers and ads through our websites, and via email (with your consent, where required by law);
• To perform in connection with your roles, responsibilities, and/or status as a job applicant to or an employee, owner, director, officer, or contractor of IF Direct LLC, including administering payroll, benefits, maintaining compliance with policies and procedures, and to comply with health and safety and occupational health obligations;
• To help maintain the safety, security, and integrity of our business, including all products and services, and to respond, where necessary, to requests from regulators and law enforcement or as otherwise required by applicable law, regulation, court order, or similar demand;
• As described to you when collecting your personal information or as otherwise set forth in the CCPA; and
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of IF Direct LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by IF Direct LLC is among the assets or business operations transferred.

Personal Information Disclosed for Business Purposes

We have disclosed the categories of personal information listed above for business purposes to the following categories of parties within the last 12 months (excluding disclosures we may be prohibited from reporting under applicable law):

• Our affiliated entities and unaffiliated service providers to help conduct our business; and
• Third parties to whom you direct or authorize us to disclose your personal information, independent of or in connection with products and services we provide to you.

IF Direct LLC does not and will not sell your personal information.

Your CCPA Data Rights

The CCPA provides consumers with certain data rights with respect to the personal information businesses collect. You may exercise any of the listed data rights (subject to certain exceptions and limitations), by following the “Instructions for Submitting a Verifiable CCPA Data-Rights Request” provided below.

You have “Rights to Know”:

1. The specific pieces of personal information we have collected about you;
2. The categories of personal information we have collected about you;
3. The categories of sources from which your personal information is collected;
4. The categories of personal information that we have disclosed for a business purpose about you;
5. The categories of third parties to whom personal information was disclosed for a business purpose; and
6. The business or commercial purpose for collecting personal information.

You also have the right to “Request to Delete” your personal information: You may request that we delete personal information about you that we have collected from you (unless an exception applies or deletion is otherwise restricted or prohibited by law, rule, or regulation).

Non-Discrimination

You have the right not to receive discriminatory treatment for exercising any of these data rights.

IF Direct LLC does not discriminate against any consumer for exercising their rights under the CCPA.

CCPA Data Rights Are Not Available for Certain Personal Information

CCPA data rights are not available for personal information we collect about you in the course of you acting as a job applicant to or an employee, owner, director, officer, or contractor of IF Direct LLC, including, in these contexts, your emergency contact information and personal information that is necessary for us to retain to administer benefits for another person relating to you acting as a job applicant to or an employee, owner, director, officer, or contractor of IF Direct LLC. Any personal information we collect and use will only be used within the context of your role or former role in these capacities.