GFG Securities, LLC Website Privacy and Cookie Policy

V.1.2 Effective June 1, 2024

This Privacy and Cookie Policy (this “Policy”) describes the ways in which GFG Securities, LLC, a Delaware corporation (“GFG Securities, LLC”), collects, uses, and discloses information about you, including personally identifiable information, in connection with your access to the website accessed via https://www.gfgsecurities.com (the “Website”) and the information, content, and features provided through the Website (the “Services”). Throughout this Policy, “you” refers to the individual or entity that is visiting the Website or otherwise interacting with us. By accessing the Website, you consent to the use of your information as set forth in this Policy. If you are a customer of GFG Securities, LLC or an end user accessing an investor portal, additional and/or different privacy terms may apply to you, as indicated at the time you set up an account to access the restricted portions of the Website.

1. Scope

GFG Securities, LLC provides you access to the Website and the Services, subject to the Website’s Terms of Use. In the course of providing access to the Website and the Services, GFG Securities, LLC may collect “Personal Information,” which means any information relating to an identified or identifiable natural person (a “data subject”) (an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person). GFG Securities, LLC does not collect your Personal Information except to allow you to access the Website and to provide the Services or as specifically set forth in this Policy. This Policy applies only to information collected through the Website or through communications resulting from the use of the Website. Communications with customers are controlled by a separate agreement and regulated by law, including FINRA and the SEC.

2. Changes to this Policy

GFG Securities, LLC reserves the right to update this Policy from time to time by posting a new Policy on this page, and in some cases where changes are material, GFG Securities, LLC may also contact you via electronic mail or post a notice on the homepage to let you know of such changes. You are advised to consult this Policy regularly for any changes. Your continued use of the Website after such changes have been made constitutes acceptance of those changes. You will be directed to the applicable Policy upon your creation of an account which allows you access to any restricted portion of the Website.

3. Collection of Information

• Information that You Provide: GFG Securities, LLC collects any information that you voluntarily provide, including when you submit information requesting a demonstration, join the e-mail list, apply for a job, or use the Services available through the Website. Information that you may provide includes your email address, name, phone number, location, details of your education, online social accounts, and professional resume or CV. GFG Securities, LLC may also collect information that you provide by electronic mail, telephone, or other means. The information collected is only that which you choose to provide and control.
• Automatically Collected Information: GFG Securities, LLC may automatically collect certain technical information from your computer or mobile device when you use the Website, such as your Internet Protocol address, your web browser type and version, the name and version of your operating system, the pages you view on the Website, the pages you view immediately before and after you access the Website, and the search terms you enter on the Website. This information allows GFG Securities, LLC to recognize you and personalize your experience if you return to the Website using the same computer or mobile device, and to improve the Website and the Services.
• Information about Legal and Other Materials: In addition, GFG Securities, LLC may collect technical information from your computer or mobile device concerning your receipt of communications, access to materials, and approval or execution of contracts, consents, or other statements or agreements by means of the Website, including the Website’s Terms of Use and this Policy.
• Cookies: GFG Securities, LLC may collect this information using “cookies,” which are small text files that the Website saves on your computer or mobile device, or similar technologies. You can disable cookies in your browser settings, but doing so may affect the functionality of the Website. GFG Securities, LLC may also collect information from the Website and the email list using “web beacons,” which are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website tied to the web beacon, and a description of a website tied to the web beacon or using unique links that can distinguish when individual users click the link. Web beacons and unique links, alone or in conjunction with cookies, may help GFG Securities, LLC compile information about your interactions with electronic mail sent to you in connection with the Services. For further information, see the Cookie Policy.
• Cross-Site Tracking: GFG Securities, LLC does not utilize technical measures on the Website to track your activities across different websites or online services, whether you configure your browser’s Do Not Track feature or otherwise. The Website does utilize third-party application programming interfaces controlled by third parties, such as marketing tracking services, that may attempt to track your activity across other sites that utilize those interfaces.

4. Use and Disclosure of Information

GFG Securities, LLC may collect, use, share, and otherwise process your personal information for a number of purposes, including, but not limited to:

• Accessing the Website and Providing and Improving the Services: GFG Securities, LLC uses your Personal Information to provide you with the Services, or products, services, or information related to the Website. The legal basis for such use is the Website’s Terms of Use and this Policy.
• Analysis: GFG Securities, LLC uses your Personal Information for improving the quality of the Website and/or the Services and for internal research and development. We share data with third parties such as service providers and partners who assist in delivering our services. These third parties include Google Analytics, Google Adwords, and Constant Contact. The legal basis for such use is the Website’s Terms of Use and this Policy, and GFG Securities, LLC’s legitimate interest in improving the Website and Services.
• Marketing: If you submit your information to GFG Securities, LLC, GFG Securities, LLC may provide you with information about the Website, Services, or required notices. In addition, GFG Securities, LLC may use collected information for delivering marketing communications that may be of interest to you. GFG Securities, LLC may share your Personal Information with its parents, affiliates, or subsidiaries for marketing purposes. GFG Securities, LLC does not sell or share your Personal Information with other companies so that they can market to you. You have the right to ask GFG Securities, LLC not to process your Personal Information for marketing purposes.Users may opt out of data collection or delete their information by following the steps outlined by contacting our support team at info@gfgsecurities.com. Users who do not provide their data may face limitations in accessing certain services or features on our website.
• Security: GFG Securities, LLC may use your Personal Information for safety and security purposes, including sharing of your information for such purposes, when it is necessary to pursue GFG Securities, LLC’s legitimate interests in ensuring the security of the Website and Services.
• Service Providers: GFG Securities, LLC engages third-party service providers to assist in operating and marketing the Services. This may include entities such as WPEngine and data processors who provide specific services to assist GFC Securities, LLC in providing services to you.
• Other Disclosure: GFG Securities, LLC may disclose Personal Information about you to others under certain circumstances.

5. Storage

• Jurisdiction: Information collected through the Website will be stored in, processed in, and subject to the laws of the United States. Information collected from outside the United States may be transferred internationally, primarily to servers located in the United States. Such transfers are done in a manner that is compliant with data privacy and protection laws including the most current version of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) known as the General Data Protection Regulation (GDPR).
• Security: GFG Securities, LLC is committed to protecting your information from unauthorized access, use, or disclosure and will use commercially reasonable means to secure PII it collects through the website. However, you should understand that there is no guarantee of data privacy or security.
• Retention: GFG Securities, LLC will not retain personal data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. We periodically review retention periods to ensure compliance.
• Data Deletion: When data is no longer needed, it is securely deleted using methods such as data wiping and destruction of physical media.

6. Right to Access and Correct Data

You have the right to access and correct or delete the Personal Information GFG Securities, LLC has collected about you. Users can exercise their data rights by contacting our support team via email at info@gfgsecurities.com or through their account settings on our website.

7. Notice to European Residents: General Data Protection Regulation

If you are located in the European Economic Area (EEA), GFG Securities, LLC’s legal basis for collecting and using the Personal Information described in this Policy depends on the Personal Information GFG Securities, LLC collects and the specific context in which GFG Securities, LLC collects it. Our Data Protection Officer (DPO) can be reached at help@crstc.com for any privacy concerns.

8. Notice Regarding U.S. Data Privacy Laws. US Data Privacy Laws may afford consumers certain rights with respect to the collection, access and use of the Personal Information. US Data Protection Laws include: California Consumer Privacy Act (CCPA) (Cal. Civ. Code §§ 1798.100 – 1798.199) of 2018, including as modified by the California Privacy Rights Act (“CPRA”); the Colorado Privacy Act C.R.S.A. § 6-1-1301 et seq. (SB 21-190); the Connecticut Data Privacy Act, S.B. 6 (Connecticut 2022); the Florida Digital Bill of Rights, Fl. Stat. 501.701 et seq (effective 1 July, 2024); the Utah Consumer Privacy Act, Utah Code § 13-61-101; the Virginia Consumer Data Protection Act, Va. Code Ann. § 59.1-575 et seq. (SB 1392); and any implementing regulations thereto.

9. Notice to California Residents: California Consumer Privacy Act

This section supplements the information contained in this Policy and applies solely to visitors, users, and others who reside in the State of California.

Under the California Consumer Privacy Act (CCPA), California residents have the right to request access to their personal information, request deletion of their personal information, opt out of the sale of their personal information, and not be discriminated against for exercising these rights. If you are a California resident and wish to exercise your CCPA rights, please contact us at contact@gfgsecurities.com.

10. Notice to Colorado Residents: Colorado Privacy Act

This section supplements the information contained in this Policy and applies solely to visitors, users, and others who reside in the State of Colorado.

Under the Colorado Privacy Act (CPA), Colorado residents have the right to access their personal information, correct inaccuracies in their personal information, delete their personal information, obtain a copy of their personal information, and opt out of the processing of their personal information for targeted advertising, the sale of personal information, or profiling. If you are a Colorado resident and wish to exercise your CPA rights, please contact us at contact@gfgsecurities.com.

11. Notice to Connecticut Residents: Connecticut Data Privacy Act

This section supplements the information contained in this Policy and applies solely to visitors, users, and others who reside in the State of Connecticut.

Under the Connecticut Data Privacy Act (CTDPA), Connecticut residents have the right to access their personal information, correct inaccuracies in their personal information, delete their personal information, obtain a copy of their personal information, and opt out of the processing of their personal information for targeted advertising, the sale of personal information, or profiling. If you are a Connecticut resident and wish to exercise your CTDPA rights, please contact us at contact@gfgsecurities.com.

12. Notice to Utah Residents: Utah Consumer Privacy Act

This section supplements the information contained in this Policy and applies solely to visitors, users, and others who reside in the State of Utah.
Under the Utah Consumer Privacy Act (UCPA), Utah residents have the right to access their personal information, correct inaccuracies in their personal information, delete their personal information, correct inaccurate information, obtain a copy of their personal information, and opt out of the processing of their personal information for targeted advertising, the sale of personal information, or profiling. If you are a Utah resident and wish to exercise your UCPA rights, please contact us at contact@gfgsecurities.com.

13. Notice to Florida Residents: Florida Digital Bill of Rights

This section supplements the information contained in this Policy and applies solely to visitors, users, and others who reside in the State of Florida.

Under the Florida Digital Bill of Rights (FDBR), Florida residents have the right to access their personal information, correct inaccuracies in their personal information, delete their personal information, obtain a copy of their personal information, and opt out of the processing of their personal information for targeted advertising, the sale of personal information, or profiling. If you are a Florida resident and wish to exercise your FDBR rights, please contact us at contact@gfgsecurities.com.

14. Children’s Privacy

The Website and Services are not directed to children under the age of 13, and GFG Securities, LLC does not knowingly collect Personal Information from children under the age of 13.

15. Contact Information

If you have any questions about this Policy, please contact us at contact@gfgsecurities.com.

16. Venue and Jurisdiction

This Policy and any disputes arising out of or related to it shall be governed by and construed in accordance with the laws of the State of Delaware without regard to its conflict of law principles. Any legal suit, action, or proceeding arising out of, or related to, this Policy or the Website shall be instituted exclusively in the federal courts of the United States or the courts of the State of Delaware, in each case located in New Castle County, Delaware.

17. Effective Date

This Policy is effective as of June 1, 2024, and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.