VTS’s is a fully disclosed securities Broker Dealer (“BD”) in accordance with all laws, rules, and regulations applicable to a securities BD and the business conducted by a securities BD. As a BD VTS’s principal business is to facilitate the execution of orders received on a solicited and unsolicited basis for both its institutional and non-institutional clients. VTS has clearing agreements with APEX Clearing Corporation, which provides defined “back office” securities clearing, custodial and processing services.
In its capacity as a securities BD, VTS receives and/or comes into contact with certain non-public personal information concerning its current and/or former customers, including but not limited to certain non-public personal information related to the securities account(s) that customers open and/or maintain with VTS. Any and all such non-public personal information related to such customers and/or such customers’ securities account(s) is hereinafter referred to as “non-public personal information”. VTS receives and/or comes into contact with the non-public personal information only for purposes of conducting its business as described above. For convenience herein, “you” or “your” refers to any and all customer(s) described above.
VTS DOES NOT SELL YOUR NON-PUBLIC PERSONAL INFORMATION COLLECTED.
In conducting its business as described above, VTS collects (or may collect), for example, the following types of non-public personal information:
NON-PUBLIC PERSONAL INFORMATION DISCLOSED TO AFFILIATES AND NON-AFFILIATED THIRD PARTIES.
VTS discloses to its affiliates and non-affiliated third parties non-public personal information only in connection with VTS providing securities BD services. Such disclosures include, among other things, information related to transactions, settlement, billing and payment. Such disclosures may be provided to affiliates and non-affiliated third parties: (i) as required or necessary to carry out fully and properly the securities business of VTS (such as, for example, disclosures to affiliated and non-affiliated third party service providers supplying to VTS computer related, document processing and delivery, and data maintenance or processing services, and disclosures to non-affiliated third parties such as clearing agencies and entities); (ii) as required by law or legal process; or (iii) with your consent.
VTS will disclose non-public personal information about the former customers of VTS only as permitted and/or required by law or legal process, or with your consent.
CONFIDENTIALITY AND SECURITY OF NON-PUBLIC PERSONAL INFORMATION
VTS is committed to implementing and maintaining commercially reasonable and appropriate measures to maintain your non-public personal information in a secure and confidential fashion. VTS’s information and security procedures may include, but are not limited to the following features;
VTS regularly reviews, revises and updates its information security program to account for changes in technology.
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