Privacy Statement

Trade-PMR Privacy Statement

This Privacy Statement was last modified and is in effect as of June 1, 2026 for Trade-PMR, Inc. (“TradePMR”). TradePMR respects your privacy and is committed to protecting the privacy and confidentiality of your Personal Data.

This Privacy Statement governs how TradePMR collects, uses, maintains, discloses, and otherwise processes Personal Data collected when you access or use our website or Fusion Platform (the “Services”). “Personal Data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, household, or device, and includes information referred to as “personally identifiable information” or “personal information” under applicable privacy and data protection laws.

In this Privacy Statement, references to “you” include customers, prospective customers, website visitors, and other individuals who interact with our Services. In some contexts, we may use the term “customer” to refer specifically to an individual who obtains or has obtained a financial product or service from TradePMR.

Please read this Privacy Statement, as well as our Gramm-Leach-Bliley Act Financial Privacy Notice, carefully to understand our policies and practices regarding your information. If you do not agree with our policies and practices, you should not use our Services. By accessing or using our Services, you acknowledge that your information will be handled as described in this Privacy Statement. This Privacy Statement may change from time to time (see Changes to Our Privacy Statement), and your continued use of the Services after we post updates is subject to the updated Privacy Statement.

If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Data. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/privacy-laws and see the Privacy Notice for California Residents section VIII of this Privacy Statement.

I. Information we collect and how we collect it

A. Categories of Personal Data We Collect

Depending on how you interact with us, we collect and, during the preceding 12 months, have collected the following categories of Personal Data about you:

• Identifiers (e.g., name, mailing address, email address, phone number, account username, IP address, and other online identifiers)

• Characteristics of protected classifications under applicable law (e.g., age, gender, marital status, citizenship, or veteran status, where collected and permitted by law)

• Financial and account information (e.g., account numbers, account balances, transaction details, payment information, and information contained in applications and account documentation)

• Commercial information (e.g., products or services considered or obtained, transaction history, marketing preferences, marketing collateral requested, and webinar or event registrations)

• Professional or employment-related information (e.g., employment status, employer, job title, industry, and related business contact information)

• Internet or other electronic network activity information (e.g., browsing history, search history, device information, log data, and interactions with our website, applications, advertisements, or communications)

• Geolocation data (e.g., approximate location information derived from your IP address or device settings)

• Inferences drawn from other Personal Data we collect to create a profile about your preferences, characteristics, behavior, or likely interests

• Sensitive Personal Data and other verification information (e.g., government-issued identifiers, date of birth, biometric or authentication-related information where used for security, and information needed to verify identity or comply with legal obligations)

• Audio, electronic, visual, or similar information (e.g., call recordings, chat contents, messages, or other communications with us, where permitted by law).

B. Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

Information we collect directly from you

• When you provide information in applications and related forms to obtain a financial product or service.

• When you provide information through applications, forms, questionnaires, free-form text boxes, surveys, chats, or other communications with us.

• When you contact us.

Information we collect automatically when you use our services

• Through cookies and similar technologies (see “Tracking Tools” section VI below).

• If you use a location-enabled browser or device and have permitted location access, we may receive information about your location and device.

• If you access applications, portals, or software we make available, we may receive information transmitted from your device for the purpose of providing the relevant Services, such as device identifiers, login activity, crash data, and information about updates or alert notices.

Information from publicly available sources

• Information from the media, public databases, and other records or information made available by federal, state, local, or other governmental entities, as well as other publicly available sources.

Information we collect from third parties

• Information obtained from advisors, custodians, administrators, introducing or clearing firms, and other third parties involved in providing a Service to you.

• Third-party reports and data, such as demographic, identity verification, fraud prevention, or other information relevant to the Services.

• Information about your relationship with us or with service providers supporting the Services, such as products or Services purchased, account numbers, transaction information, and balances.

• Analytics providers that help us understand how you engage with our website, applications, and other Services.

• Marketing, referral, and lead-generation providers that help us identify prospective users and understand interest in our Services.

• Service providers and partners that help us with marketing, advertising, campaign measurement, and understanding how you interact with our websites, applications, products, Services, advertisements, or communications.
  
  

II. How and Why We Use Your Information

We collect, use, and disclose Personal Data about you for the following business and commercial purposes:

Providing, customizing, and improving our Services

• Creating, administering, maintaining, and servicing your account or other user profiles, including onboarding and identity verification.

• Processing orders, transactions, payments, transfers, and other activities you request or authorize.

• Providing you with the products, services, or information you request, including support and assistance for the Services.

• Improving the Services, including testing, research, internal analytics, and product development.

• Personalizing the Services, website, and communications based on your preferences.

• Performing fraud protection, security, and debugging.

• Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).

Marketing our Services

• Marketing and selling the Services.

• Showing you advertisements, including interest-based or online behavioral advertising.

Corresponding with You

• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about TradePMR or our Services.

• Sending emails and other communications according to your preferences or that display content that we think will interest you.

Meeting Legal Requirements and Enforcing Legal Terms

• Fulfilling our legal obligations, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities.

• Protecting the rights, property, or safety of you, TradePMR, or another party.

• Enforcing agreements with you and resolving disputes.

• Responding to claims that any posting or other content violates third-party rights.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing notice to you.

III. How We Share Your Personal Data

We disclose your Personal Data to the following categories of recipients:

Service Providers who help us provide the Services or perform business functions:

• Companies engaged to work with us, such as our clearing firm, third-party administrators and vendors hired to effect, administer, or enforce a transaction or service that you request or authorize; to facilitate enhanced customer service; to develop or maintain software; to perform marketing research; or to provide us with demographic information to develop marketing plans.

• Consumer reporting agencies in connection with your application or renewal of any Services subscribed or purchased.

• Analytics providers.

• Payment processors.

• We require these companies to maintain the confidentiality of your information and use it only for the purpose for which it was provided.

Your Advisor with whom you work to obtain Services.

Your Advisor’s successors and assigns for business and regulatory purposes after the termination of your customer relationship.

Business partners with which we share common ownership or who partner with us in offering various services, joint promotional offers, or opportunities.

Advertising partners who help us market our Services:

• Marketing providers.

• Ad networks.

Substantial corporate transactions in which we may disclose information about you in connection with a substantial corporate transaction, a merger, consolidation, reorganization, financing, change in control or acquisition of all or a portion of our business by a third party, or in the unlikely event of a bankruptcy or similar proceeding.

Law enforcement, government authorities, and regulatory authorities, as necessary to comply with applicable law, legal process, or regulatory obligations (including in response to a subpoena, to prevent fraud, and to comply with rules of, or inquiries from, industry regulators or law enforcement).

We recognize that our customers’ relationship with their Advisor is important. If the customer is a participant of an employer-sponsored plan, the customer’s Advisor may be under an agreement that restricts the transfer of the customer’s Personal Data and/or the customer’s employer-sponsored plan account to any new firm.

IV. Retention of Information

We retain your personal information for as long as necessary to achieve the original purpose(s) for which we collected it and to comply with relevant laws. For example, we may retain certain data for the duration of your relationship with us and for a period of up to 7 years after the relationship ends in order to comply with our obligations as a regulated financial institution.

We may also keep your personal data for a longer period if required by law, in connection with an ongoing or potential claim, or for another legitimate legal or regulatory reason.

V. Data Security

We use a combination of physical, technical, and organizational measures to help safeguard Personal Data under our control. A unique user ID, password, and multi-factor authentication challenge are required to access certain Services. It is your responsibility to protect your username, password, and multi-factor authentication device.

We limit access to customer information to employees and your Advisor or agent, and their successors and assigns, who may need it to fulfill their obligation to you for the Services for which you have subscribed or purchased, or to comply with federal or state laws, statutes, or regulations.

Employees of TradePMR are trained to respect the confidentiality of your Personal Data and are required to keep such information confidential and secure.

We will notify affected individuals of unauthorized access to their Personal Data in accordance with applicable law. We may delay or withhold notification where permitted by law, including where we determine that notification is not required under applicable legal standards.

VI. Tracking Tools

Our Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser or client, tell us how and when you access or use our Services, analyze trends, and operate and improve our Services.

We respect Global Privacy Control (GPC) signals. If your browser sends a GPC signal, we will treat it as a request to opt out of the sale or sharing of your personal information.

We may insert cookies or similar technologies in some of our correspondence with users, where permitted by law. We use these technologies to collect information about you and your visit, such as the date and time visited, length of time on site, pages visited, and general information about the device.

We may use third parties to target relevant advertising on other sites based on your online activity and interests. For more information about interest-based advertising, please visit Digital Advertising Alliance or the Network Advertising Initiative.

You can opt-out of seeing personalized ads by (i) declining marketing trackers on the cookie banner; (ii) setting browser-level GPC signals; or (iii) using opt-out tools like those offered by the DAA or the NAI opt-out tool. Please note you will still see ads even if you opt-out, but they will not be personalized.

VII. Notice to International Users

Our Services are targeted for users in the United States of America and Canada. If you access our Services from outside the United States, your Personal Data may be transferred to, stored in, and processed in the United States or other jurisdictions where our service providers operate. Those jurisdictions may not provide the same level of data protection as your home jurisdiction. By using our Services, you acknowledge that your Personal Data may be transferred to and processed in the United States and on its servers located in the United States of America as described in other jurisdictions, subject to applicable law and this Privacy Statement.

VIII. Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in our Privacy Statement and applies solely to all visitors, users, and others who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended (the “CCPA”). This notice does not apply to employment-related Personal Data collected from California-based employees, job applicants, contractors, or similar individuals.

The categories of personal information we collect (and have processed over the past 12 months) include: identifiers (such as IP address), internet or other electronic network activity information (such as website usage and engagement with promotional messages and ads), inferences, and as otherwise described in Categories of Personal Data We Collect section I, A. We do not knowingly collect information that is considered “sensitive” under State Privacy Laws and we do not use or disclose sensitive personal information for the purpose of inferring characteristics about you.

We disclose this information with the categories of third parties described in How We Share Your Personal Data section III. The following table describes for each applicable category of personal information collected that is subject to these State Privacy Laws, the categories of third parties to which such information may have been “sold” or “shared” (i.e., shared for targeted advertising) over the past 12 months.

We do not knowingly “sell” or “share” personal information about individuals under the age of 16.

A. Your Rights and Choices

Depending on the nature of your relationship with us, and the products or Services you use, your personal information may be subject to different privacy laws and have the following rights and choices.

Access

You may have the right to request that we disclose certain information to you about our collection and use of your Personal Data over the past 12 months. Once we receive and confirm your verifiable request, we will disclose to you (to the extent required by law):

• The categories of Personal Data we collected about you.
• The categories of sources for the Personal Data we collected about you.
• Our business or commercial purpose for collecting that Personal Data.
• The categories of third parties with whom we share that Personal Data.

Deletion

You may have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete your Personal Data from our records, unless an exception applies. For example, if your relationship with us is limited to personal financial services (such as maintaining a brokerage account), the personal information we collect about you is generally covered by federal financial privacy law rather than state privacy laws.

Personal Data Sales and Sharing

The CCPA defines a “sale” as the disclosure of Personal Data for monetary or other valuable consideration and a “share” as certain disclosures for cross-context behavioral advertising. TradePMR does not offer an opt out from the sale or sharing of Personal Data because we do not and have not, within the preceding 12 months, sold or shared Personal Data in a manner that triggers the CCPA’s opt-out requirements.

B. Exercising Access and Deletion Rights

To exercise the rights described above, you or your Authorized Agent (defined below) may submit a request via email to our Compliance Department at compliance@tradepmr.com.

You may authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

C. Responding to Requests

When certain financial privacy laws apply, Personal Data may be exempt from, or outside the scope of, Access Requests and Deletion Requests. For example, information subject to certain federal privacy laws, such as the Gramm-Leach-Bliley Act (“GLBA”), is exempt from CCPA Requests. As a result, in some cases, we may have no obligation to accept any Data Subject Requests (“DSRs”), and in other cases, we may have no obligation to honor a particular DSR, because of the nature of the personal information that is collected or maintained.

D. Non-Discrimination

We will not discriminate against you for exercising any of your state privacy law rights. We will not:

• Deny you goods or services.
• Charge you different prices or rates for our Services, including through granting discounts or other benefits, or imposing penalties.
• Provide you with a different level or quality of service.
• Suggest that you may receive a different price or rate for our Services or a different level or quality.

TradePMR does not sell or share your Personal Data; therefore, CCPA-permitted financial incentives are not applicable.

IX. Changes to Our Privacy Statement

We reserve the right to make corrections or updates to this Privacy Statement at our discretion from time to time. When we do so, we will post the updated Privacy Statement on our website and update the Privacy Statement’s effective date. We may notify you of material changes to this Privacy Statement by placing a prominent notice at the top of the Privacy Statement for thirty (30) days or by other appropriate means. The date this Privacy Statement was last revised is identified at the top of the page. We encourage you to periodically review this Privacy Statement.

X. Contact Information

If you have any questions, concerns or comments about the ways in which we collect and use your information as described in this Privacy Statement, your choices and rights regarding such use, or if you wish to exercise your rights under California law, please feel free to contact our Compliance Department at compliance@tradepmr.com.