INTERCOASTAL CAPITAL MARKETS, INC. PRIVACY POLICY

OUR COMMITMENT TO YOU AND WHO WE ARE
Intercoastal Capital Markets, Inc. is a U.S. registered broker dealer under the regulatory jurisdiction of FINRA, the SEC and the U.S. Government. Our relationship with you is our most valuable asset. We, therefore, would like to assure you that your personal information is safe in our hands. We take the utmost care to maintain the confidentiality of your private information, whether it is provided to us in person, by telephone, in writing, through our financial correspondents, or by other means. We do not sell our clients’ information to any third parties, nor do we disclose client information to parties that are unaffiliated with Intercoastal Capital Markets Inc., unless that information is necessary to provide our products and services to you or its disclosure is otherwise permitted by law. For example, at times we may need to share your information with regulatory agencies, federal, state or local authorities, or credit reporting agencies. These entities are required by law or by contractual obligation to us to maintain the confidentiality of your private information. These are the commitments Intercoastal Capital Markets Inc. makes to you regarding the privacy of your personal information.

WHAT DATA AND INFORMATION DOES INTERCOASTAL CAPITAL MARKETS, INC. COLLECT ABOUT YOU AND HOW IS IT COLLECTED?
In the course of doing business with you, we will need to obtain certain personal and confidential information about you. This information is obtained in direct interactions with you including phone conversations and forms you may complete. This information can be separated into the following categories:

Personal Information — This information is your identity and contact info, which may include among other things, your name, address, phone number, Social Security number, marital status, spousal information if married, your occupation and employer, your tax bracket, name, address, and Social Security number of your beneficiaries, personal financial information that you provide to us on new account applications or other forms, or any additional information that you wish to share with Intercoastal Capital Markets Inc.

Information Regarding Your Account History — As part of establishing a business relationship with you, we collect and maintain information regarding your investment transactions, financial data and other activities that occur here at Intercoastal Capital Markets Inc. This includes items such as your account balance, payments, withdrawals, account activity, financial profile and correspondence with you.

Credit and Securities Industry Background Information — We may obtain a consumer or securities industry report about you upon the opening of your account from a reputable consumer-reporting agency. These reports are used to verify your information, for general risk management decisions, or for any other legitimate business purpose.

Our services are not intended for children. We do not specifically collect or retain data relating to children other than information that may pertain to the type of account or information required to maintain a particular account including but not limited to a trust, retirement account, account held in trust for a minor and/or beneficiary information.

WHO MAY OBTAIN YOUR PRIVATE INFORMATION FROM INTERCOASTAL CAPITAL MARKETS, INC. AND HOW IS IT DISCLOSED?
We do not sell any of the personal information we collect about our potential, current, or former clients. We also do not provide this information to unaffiliated third parties for use in the direct marketing of their own products or services. We will only disclose the information we collect as permitted by law or as requested by you. We also may provide the above information to unaffiliated third parties when necessary to facilitate our business relationship with you or as requested or required by regulatory agencies or federal, state, or local authorities. Unaffiliated third parties may include:
Service providers, such as International FC Stone (IFCS) and Hilltop Securities, Inc. (clearing agents for Intercoastal), and the companies that print your account statements that maintain your information in electronic form so you, your salesperson and trader may view your account on-line, and that provide support to client accounts.

Financial service providers, such as financial advisers, money managers, money funds, mutual funds, or trust service supporters, should you choose to participate in these types of investments or services

Information providers, such as consumer credit reporting or securities industry background-checking agencies.

Professionals, such as accountants, tax consultants, and lawyers who may be involved in providing trust, estate, or other financial planning services for you.

Regulatory agencies and legal authorities, such as the Securities and Exchange Commission or other financial industry regulators. These agencies will make official requests from time to time regarding customer accounts and trading activity. When these requests are made, we are obligated to provide them with all requested information. This category may also include the disclosure of information to federal, state or local authorities, courts or arbitrators, third parties in response to a summons or subpoena, and third parties in compliance with money-laundering or other laws.

The sharing of information with these entities is essential for us to fully service our clients and to satisfy our legal and regulatory obligations. All of these entities are required by law or otherwise obligated to Intercoastal Capital Markets Inc. to strictly maintain the confidentiality of your information. In addition, some of these entities may have and provide to you their own privacy policies. If our policy on disclosing information changes, we will promptly notify you in writing.

Please note for EU and UK nationals with regards to use and processing your personal data, we may need to transfer your personal data outside your domestic jurisdiction. Please be advised that whenever we may have to transfer your personal data out of the European Economic Area (EEA), we employ a similar degree of protection expected in the EEA to ensure the protection and safeguarding of your information and data.

HOW DOES INTERCOASTAL CAPITAL MARKETS INC. MAINTAIN DATA SECURITY, RETAIN DATA AND PROTECT THE CONFIDENTIALITY OF YOUR PERSONAL INFORMATION?
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We restrict access to non-public personal information about you to those employees at Intercoastal Capital Markets Inc. who need to know that information. Our employees are bound by a code of ethics requiring confidential treatment of customer information and are subject to disciplinary action if they fail to follow this code. We will retain your personal data in accordance with the prescriptions of applicable law. We also maintain physical, electronic, and procedural safeguards that comply with federal and industry standards to guard your non-public personal information. We have put in place these procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

YOUR LEGAL RIGHTS
In order to ensure that the personal data which we hold and process is correct at all times, please let us know if there are any changes to your personal data.

We acknowledge the domestic law governing the processing and security of your personal data.

With respect to EU and UK Nationals we note your particular rights to access, erase, restrict and object to our use and processing of your personal data. Please contact us using the contact information provided in this policy in the event that you wish to exercise such rights. Please note that we may require particular and additional information from you or your representative pursuant to the satisfaction of your request.

WHO SHOULD I CONTACT FOR MORE INFORMATION?
If you have any questions regarding our privacy commitment or require assistance, please call Intercoastal Capital Markets Inc. at 561-939-8282 or email us at ops@intercoastalcm.com.

If you are an EU National and UK national we acknowledge that you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Updated 6/1/19