PUBLIC VENTURES LLC

Regulation S-P Firm Privacy Statement

Privacy Disclosure Notice

Public Ventures, LLC (“Public Ventures”) shares your concerns about privacy.  We understand that you want to know how we treat personal information we obtain from you or other sources in the course of providing you with investment products and services.

What kind of personal information do we have, and where did we get it?

Most, if not all, of the personal information that we have about you comes directly from you.  Your sales representative records information that you provide, such as your name and address, financial information, investment experience, occupation and address of employer, birth date, social security number, e-mail address, phone number, etc.  We also keep and maintain records of any securities or money positions held in your account.  We may also collect personal information from outside sources, including consumer reporting agencies and CRD (Central Registration Depository) if you are, or were, associated with the securities industry.

What do we do with the personal information we have about you?

It is our policy not to disclose any personal information to non-affiliates that might use your personal information to contact you about their own products and services.  We educate our employees to protect your personal information. Within Public Ventures, your personal information is available only to those individuals who are involved in servicing your financial needs or in supervisory activities.  Your registered representative will use your personal information to help evaluate your financial position and establish appropriate investment objectives.  This information may be used, if appropriate, to make recommendations to you about specific products and services.

Under certain conditions, we may, as permitted by law and without your permission, provide personal information to persons, consultants, or servicing agents  (securities clearing organizations such as Interactive Brokers LLC, a Financial services company), regulatory or law-enforcement authorities, and persons requesting information pursuant to a subpoena or court order.

Finally, should your relationship with Public Ventures end, your personal information will remain protected in accordance with our privacy practices as outlined in this notice.

How can you find out what information we have about you?

You may ask to see or obtain a copy of any personal information we have in our records.  If any of the information is believed to be incomplete or inaccurate, you may request that we make any necessary and appropriate changes.  Please send any requests to Public Ventures, LLC, 4209 Meadowdale Lane, Dallas, TX 75229.

Other Information

Should you have any questions, concerns, or desire more information about your account, please contact your financial advisor for further assistance.  If deemed appropriate, any concerns you may have regarding the investment handling of your account may be directed to:

Public Ventures, LLC
Compliance Department
4209 Meadowdale Lane
Dallas, TX 75229
(310) 526-5006

For quality assurance, telephone conversations are recorded.

We hope you have found this communication helpful.  If you have any questions or would like more information, please don’t hesitate to contact your Public Ventures representative.

As you may know, Public Ventures, LLC and Interactive Brokers LLC (“IB”) have an agreement that IB will provide trade execution, clearing, and related activities for your account. In connection with these services, IB is required to communicate its position as it pertains to the privacy of customer information. Please review IB’s Privacy Notice below.

Interactive Brokers LLC Privacy Policy

At Interactive Brokers, we understand that confidentiality and security of the personal information that you share with us is important. That is why we have developed specific policies and practices designed to protect the privacy of your personal information. By opening an account with IB or by utilizing the products and services available through IB, you have consented to the collection and use of your personal information in accordance with the privacy notice set forth below. We encourage you to read this privacy notice carefully.

Types of personal information that we collect

In order to provide brokerage and other financial services and to comply with regulatory requirements, IB collects certain personal, nonpublic information from you. This includes information:

  • provided during the IB account application process (e.g., your name, e-mail address, telephone number, birth date, social security number, investment objectives, etc.);
  • acquired as a result of the transactions you conduct through the IB system or in connection with services offered by IB (e.g., if you participate in IB’s debit card program); and
  • received from consumer-reporting agencies.

Limits on disclosure of your personal information

We do not disclose personal, nonpublic information to individuals or entities that are not affiliated with IB, except as provided by law. For example, among other reasons, we may disclose or report such information: where necessary to authorize, effect, administer or enforce transactions that you request or authorize; to maintain and administer your account; to provide you with account confirmations, statements and records; to maintain appropriate archival records; where we believe that disclosure is required by applicable law, rules or regulations; to cooperate with law enforcement, regulatory or self-regulatory organizations; in connection with resolving disputes arising from your transactions or services we provide to you; to enforce our customer and other agreements; to meet our obligations; or to protect our rights and property. As long as consistent with applicable securities laws and regulations, we may share anonymized account information or anonymized delayed-order information with third parties (and/or share such information among our affiliates) for the purpose of analysis, research, market data compilation, product creation, establishing order routing and execution relationships, or for any other lawful purpose.

We safeguard the confidentiality of your personal information in a number of ways. For example:

  • We do not sell or license lists of our customers or the personal, nonpublic information that you provide to us.
  • We restrict access to the personal, nonpublic information that you have shared with us to those IB employees, agents and affiliates who need to know such information in connection with the services that IB or an IB affiliate provides to you. This may include third party vendors IB utilizes to provide services to you.
  • We maintain strict employment policies that prohibit employees who have access to your personal, nonpublic information from using or disclosing such information except for business purposes.
  • We take substantial precautions to safeguard your personal, nonpublic information. For example, the IB system can be accessed only by authorized IB personnel via valid user names and passwords. In addition, our Internet-based systems include security measures such as encryption and firewalls.

If you choose to subscribe to any of Interactive Brokers Investors’ Marketplace suite of third-party services that are provided through the IB website, we may disclose such information to the service providers as necessary for them to provide the services that you have requested. IB requires these service providers to enter into confidentiality agreements with IB that limit their use of the information that they receive. Such agreements prohibit the service provider from using IB customer information that they receive other than to carry out the purposes for which the information was disclosed.

Collection and use of non-personal information

Through the use of “cookies” and similar tracking technologies, IB may collect and use certain non- personal information related to your use of our website, such as preferences and web browsing patterns. By providing IB with a better understanding of how you and others use IB’s website and other web services, cookies enable IB to improve the navigation and functionality of its website and to present you with the most useful information and offers. We may share this information with third parties who serve ads on behalf of us and others on non-affiliated websites. IB may also permit other companies or their third-party ad servers to set cookies on your browser when you visit an IB website. IB does not sell information obtained from cookies to unaffiliated third parties. You may change the cookie settings through your web browser. Disabling cookies may affect the performance and functionality of the IB website and other websites.

If you have any questions about these policies, please contact IB Customer Service through the IB website at www.interactivebrokers.com/help.

Please refer to the Interactive Brokers Privacy Policy for further information.