Privacy Policy

Effective Date: 7/1/2025

OVERVIEW

Sequoia Brokerage ("Company," "we," "us," or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our brokerage services, website, mobile application, and related services (collectively, the "Services").

INFORMATION WE COLLECT

Personal Information

We collect personal information necessary to provide brokerage services, including:

Full legal name, date of birth, and Social Security number

Contact information (address, phone number, email address)

Employment information and income details

Financial information (bank account details, investment experience, financial objectives)

Government-issued identification documents

Tax identification numbers

Account and Transaction Information

Account balances, holdings, and transaction history

Trading patterns and investment preferences

Communications with our representatives

Payment and billing information

Technical Information

IP address, browser type, and operating system

Device identifiers and mobile network information

Website usage data and cookies

Application performance and error logs

HOW WE USE YOUR INFORMATION

We use your information to:

Open and maintain your brokerage account

Execute trades and process transactions

Provide customer service and technical support

Comply with regulatory requirements and legal obligations

Prevent fraud and enhance security

Improve our services and develop new features

Send account statements, confirmations, and regulatory notices

Conduct market research and analysis

INFORMATION SHARING AND DISCLOSURE

Regulatory and Legal Requirements

We may disclose your information to:

Securities and Exchange Commission (SEC)

Financial Industry Regulatory Authority (FINRA)

State securities regulators

Internal Revenue Service (IRS)

Other regulatory bodies as required by law

Service Providers

We may share information with trusted third parties who assist in:

Clearing and settlement services

Payment processing

Technology services and data storage

Legal and compliance services

Marketing and communications (with your consent)

Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the successor entity.

Your Consent

We will not sell, rent, or lease your personal information to third parties for their marketing purposes without your explicit consent.

DATA SECURITY

We implement industry-standard security measures including:

Encryption of data in transit and at rest

Multi-factor authentication

Regular security audits and monitoring

Secure data centers with physical access controls

Employee training on data protection

YOUR RIGHTS AND CHOICES

Access and Correction

You have the right to:

Access your personal information

Request corrections to inaccurate data

Update your contact preferences

Close your account (subject to regulatory requirements)

Marketing Communications

You may opt out of marketing communications by:

Using unsubscribe links in emails

Contacting customer service

Updating preferences in your account settings

Cookies and Tracking

You can control cookies through your browser settings, though this may affect service functionality.

DATA RETENTION

We retain your information for as long as necessary to:

Provide services and maintain your account

Comply with legal and regulatory requirements

Resolve disputes and enforce agreements

Generally, we retain account information for at least seven years after account closure, as required by securities regulations.

INTERNATIONAL TRANSFERS

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place for such transfers.

CHILDREN'S PRIVACY

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from minors.

PRIVACY POLICY UPDATES

We may update this Privacy Policy periodically. Material changes will be communicated through:

Email notifications

Website notices

Account notifications

CONTACT INFORMATION

For privacy-related questions or concerns:

Email: [email protected]