Information Collected by CMS

The categories of nonpublic personal information which CMS shall collect include:

1. information provided by the customer when opening an account, or to process a transaction, such as name, address, assets, bank information, prior trading experience, etc.;
2. information used to verify the identity of the customer, including copies of government issued identification materials such as passports, drivers licenses, and credit reports;
3. information resulting from transactions between the customer and CMS or an affiliate of CMS, such as withdrawal and deposit forms;
4. information derived from customer’s navigation and usage of CMS’s website and online platforms, including account trading statements;

Usage of Personal Information

CMS may use the information collected from you to verify your identity and contact information. CMS may also use this information to establish and setup your trading or demo account, issue an account number and a secure password, maintain your account activity, and contact you with account information.

Should you close your account, CMS will retain your information, but only use it to comply with regulatory requirements and to periodically contact you to offer you the opportunity to reactivate your account or participate in other valuable offers.

Information Disclosed by CMS and To Whom CMS Discloses the Information

CMS may share information with affiliates if the information is required to provide the product or service you have requested or to provide you the opportunity to participate in the products or services our affiliates offer.

Except for the limited circumstances described below or as otherwise permitted by law, CMS does not share nonpublic personal information about our current or former customers with any third parties.

• CMS may share nonpublic personal information with introducing brokers for translation services.  When introducing brokers provide translation services, we endeavor to protect such personal information by requiring those introducing brokers to enter into an agreement with CMS to safeguard the confidentiality of personal information.
• When a client is referred by an introducing broker, CMS generally shares nonpublic personal information concerning the account opening and maintenance process with the introducing broker who made the referral;
• CMS may engage another business or person to help us identify client and demo user needs and notify clients and demo users of product and service offerings. Use of the information shared is limited to the performance of the task we request and is not used for any other purpose.  These third parties are required to enter into an agreement with CMS to safeguard the confidentiality of personal information before they provide such services. Examples of information shared are identifying information such as name, mailing address, e-mail address and telephone number and information on account activity. 
• CMS may provide information to non-affiliated third parties, as permitted by law, in providing financial services to you. This includes a consumer reporting agency that prepares your credit report;
• CMS may provide information, as permitted by law, to government or regulatory agencies and to comply with a legal summons, court order, subpoena or a similar legal process, audit or investigation; and
• CMS may also disclose your nonpublic personal information if you authorize such disclosure.

If you do not wish to have CMS share nonpublic personal information with non-affiliated third parties pursuant to any of the provisions listed above, please opt out of those provisions by sending an e-mail to compliance@cmsfx.com or calling CMS at 646-307-4449. Opting out will apply for all financial products or services you obtain through CMS. Please note that you cannot opt out of any provisions if sharing of the information is required by law. Further, please note that an opt-out election must be made for each separate account you hold at CMS or with any CMS affiliates.

Confidentiality and Security Procedures

Only those staff members for whom the information is necessary to complete a given transaction shall possess the authority to access the information. CMS, its personnel, and its affiliates shall strictly adhere to security practices and procedures to ensure the confidentiality of its customers’ information.

CMS maintains numerous safeguards that comply with Federal regulations to guard your nonpublic personal information including the use of encryption technology, firewalls and authentication systems (usernames and passwords).

CMS will continue to protect the privacy of former customers’ nonpublic personal information in the same manner as when they were customers. Unlike current customers, however, former customers will not receive annual privacy notices.

CMS will provide a notice of our privacy policy annually, as long as the customer maintains an account with CMS. CMS reserves the right to make changes to this policy. This policy may always be reviewed on www.cmsfx.com.

Cookies

CMS may set cookies and other data capture mechanisms on your computer that allow us to store data about your visit. Cookies help us learn which areas of our site are useful and which areas need improvement. You may configure your browser to prevent cookies from being set on your computer. If you do so, you may still access the website but certain features may be disabled and/or not function properly.

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Access to the Personal Data we may hold about you.  You have the right to request a copy of the data we hold about you and to have any inaccurate data about you corrected.  For more information, please send an email to compliance@cmfsx.com.

Opt Out. You are not required to supply any of the personal information that we may request.  However, failure to do so may result in CMS not being able to open or maintain your account.