Terms and Conditions

Disclosure of Nonpublic, Personal Information

In November 2000, Congress passed legislation to modernize the laws governing the financial services industry. Included were several provisions to enhance the customer privacy protections that have been the hallmarks of securities firms, banks, and insurance companies.

As of July 1, 2001, all financial institutions had to clearly, conspicuously, and annually disclose their policies for collecting and sharing nonpublic, personal information. Specifically, these policies must disclose:

• The types of information we share
• The types of third parties we share information with, and
• Information about our privacy policies and practices.

BIA Capital Strategies, LLC (“BIA”) has created this privacy statement with respect to its website in order to demonstrate its firm commitment to privacy. The following discloses the information gathering and dissemination practices for this website

We collect a variety of nonpublic personal information from you, including:

• Information we receive from you through correspondence and other communications with us; and
• Information about your transactions with others or us.

At times we require users to provide contact information (such as name and email address), unique identifiers (such as social security number), and financial information (such as income and tax figures) to provide the financial services requested. The customer’s contact information is used to contact the visitor when necessary, such as sending promotional material. Users may opt-out of receiving future mailings or emails. Financial information collected is used to check the new account applicant’s qualifications, to bill customers for products and services, and for other internal purposes.

This information is required in order to conduct business with you. The information we gather is available to employees of the BIA Capital Strategies, LLC and its affiliates on a “need to know” basis. We also share information with certain unaffiliated third parties with whom we must in order to conduct business with you. These third parties may include our clients and other companies in the financial services industry who could be interested in participating in a business transaction with you. We do not provide, disclose, or sell any nonpublic information to unaffiliated third parties for marketing purposes. We may share nonpublic personal information to protect against fraud, as required by law or by regulatory agencies having authority over us.

BIA takes reasonable precautions to protect the integrity, confidentiality, and security of personal financial information sent through any means. BIA tailors the precautions to the delivery medium selected in order to ensure that the information is reasonably secure from tampering or alteration. Before delivering personal financial information, the intended recipient must have given his or her consent to the delivery, by either manual signature or electronic means.

Our internal security procedures include physical, electronic, and procedural safeguards to protect your nonpublic personal information. Our computer database is protected by a firewall installed to protect against threats or hazards to the security and/or integrity of our records, and protect against unauthorized access to records that may harm or inconvenience our customers. Our paper-based files are stored in locations that are only accessible to employees of BIA Capital Strategies, LLC and its affiliates. When discarding paper-based records containing nonpublic personal information, we take appropriate precautions to protect your information.

As long as certain notices are provided to customers, and they do not opt-out, BIA is permitted to share our customers’ information with affiliated and nonaffiliated third parties. BIA will share nonpublic personal information of customers or former customers with affiliated third parties, as permitted by law. BIA may directly or through any affiliated third parties disclose any nonpublic personal information about a customer to a nonaffiliated third party, including as required to process a transaction, unless the customer has opted out of the privacy policy. If you prefer that we not disclose your personal information to unaffiliated third parties, you may direct us not to make those disclosures (other than disclosures permitted or required by law). You, however, may not opt out of personal information disclosed about you to any service provider necessary to effect or process any transaction in your account(s) with us (if applicable). If you wish to opt out of disclosure to nonaffiliated third parties, you may email us at cwiebe@bia.com or call us at (703) 818-8115, stating that you wish to opt out of all information sharing of your personal information.

BIA has educated our staff with regards to this privacy policy and as a general policy our staff will not discuss or disclose information regarding customer accounts, except as required or permitted by law or pursuant to regulatory request and/or authority.

BIA reserves the right to make changes to this policy at any time. To modify information or to get in touch with us regarding BIA’s privacy policy send email to cwiebe@bia.com, call (703) 818-8115 or by mail at BIA Capital Strategies, Inc., 14150 Parkeast Circle, Suite 110. Each customer and issuer that maintains an ongoing relationship with BIA will annually be provided with a copy of our Privacy Policy.

This site may, from time to time, contain links to other sites. BIA is not responsible for the privacy practices or the content of such websites.

If you are not actively conducting business with BIA Capital Strategies, LLC, we will continue to adhere to our privacy policies and practices with regard to your nonpublic personal information that was collected while we were conducting business with you.

Annual Investor Education and Protection Disclosure