PERSONAL PRIVACY
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At PHD Capital, we appreciate the trust that clients place in us and we recognize the importance of protecting the confidentiality of non-public personal information that we have in our possession. The information is used to ensure accuracy in reporting and record keeping and to carry out requested transactions. It also allows us in conjunction with our clearing firm, Legent Clearing, LLC, to create and make available new products and services to meet your financial needs. This policy is designed to protect the confidentiality of current or former customers (“you”) of PHD Capital. Keeping this information secure is a top priority for PHD Capital and keeping with recently adopted regulations, we share our Privacy Policy for retail clients:

1. This privacy policy applies to consumers whose accounts are or were maintained by PHD Capital and held in custody by Legent Clearing, LLC. We will provide our Privacy Policy to clients when they open a new account and annually after that. If we change the policy, you will be notified in advance.

2. We obtain non-public information about clients directly from each client. This includes information received as part of the account opening process (such as name, address and social security number) or as a result of other requested services. Information about client’s transactions, account positions and balances and debit card usage for those that utilize this service from Legent Clearing, LLC. This information allows us to generate confirmations, statements and other required reports on behalf of the clients. Information we may receive from credit reporting agencies that has been supplied by other brokerage firms of banking sources (such as creditworthiness and credit history).

3. The non-public personal information that is obtained is safeguarded in accordance with our internal policies and procedures. These policies permit only those employees who need to know the information in order to perform their duties to have access to customer’s non-public personal information. Legent Clearing, LLC maintains physical, electronic and procedural safeguards designed to comply with federal standards to guard client’s non-public personal information.

4. We do not disclose nonpublic personal information about former customers, except as permitted or required by law.