Understanding National Financial Services LLC: Your Privacy Matters

As a valued client, it’s important for you to understand the relationship between your broker-dealer and National Financial Services Llc (“NFS”). Your broker-dealer has partnered with NFS to provide essential clearing and other services that support your account. In providing these services, NFS is committed to maintaining the privacy of your customer information. This commitment extends to you under the following circumstances:

If you hold a retirement account through your broker-dealer, and Fidelity Management Trust Company (“FMTC”), an NFS affiliate, acts as custodian.
If your broker-dealer offers managed account services via the Fidelity Managed Account XchangeSM, a platform sponsored by Fidelity Institutional Wealth Adviser LLC (“FIWA”), a registered investment advisor and NFS affiliate.
If you maintain a brokerage account directly with National Financial Services LLC.
If you have a direct professional relationship with Fidelity Capital Markets, a division of NFS.

Throughout this privacy policy, “Fidelity Institutional Companies,” “we,” “us,” and “our” collectively refer to NFS and its affiliates mentioned above, all of which are governed by this policy.

This privacy policy is being provided to you, as a customer of a correspondent broker-dealer, on behalf of National Financial Services LLC.

Rest assured, you don’t need to take any action to benefit from these privacy protections. They are automatically in place for all customers.

In this policy, “personal information” refers to data about an individual that is collected and maintained for business purposes and can be used to identify that individual. It’s important to note that information that cannot be used to identify an individual (such as anonymous, de-identified, or aggregated data) is not considered personal information and is therefore not covered by this policy.

This policy is reviewed and updated annually to reflect any changes in our practices.

How National Financial Services LLC Obtains Your Personal Information

National Financial Services LLC, in the course of servicing your account, may receive non-public personal information about you from various sources. These sources include you directly, your broker-dealer, and other entities. Examples of how we obtain this information include:

Account Applications and Forms: When you complete applications or forms, interact with our customer service representatives, or use our websites and applications, you provide us with information.
Transactional Account Activity: Details of your trading history and account balances are essential for account management and service provision.
Consumer Reporting Agencies: To assess creditworthiness for products like margin accounts, we may obtain information from consumer reporting agencies.
Third-Party Data Sources: To verify your identity and better understand your financial needs, we may utilize information from third-party data sources.
With Your Consent: We may also receive information from other sources with your explicit consent or with the consent of your broker-dealer, such as when you transfer assets from another institution to National Financial Services LLC.

Protecting Your Information at National Financial Services LLC

At National Financial Services LLC, safeguarding your personal information is a top priority. We implement and continuously maintain a robust framework of physical, administrative, technical, and organizational security measures designed to protect your personal information. These controls are regularly updated to address evolving security requirements and technological advancements. Within Fidelity Institutional Companies, access to personal information is strictly limited to employees who require it to develop, support, offer, and deliver products and services to you, and to effectively operate our business.

How National Financial Services LLC Shares Your Information

National Financial Services LLC is committed to protecting your privacy and does not sell or share your personal information with unaffiliated third parties for their marketing purposes. We may, however, share the personal information we collect about customers, potential customers, or former customers with their broker-dealers, as well as with:

Our Corporate Affiliates: We may share information with our affiliates for business purposes and to enable them to provide services to us or your broker-dealer, such as printing, mailing, and data processing.
Unaffiliated Service Providers: We engage unaffiliated service providers, such as printing and mailing companies, securities clearinghouses, and other entities, to perform services at our direction. These providers are obligated to maintain the confidentiality of your personal information.
Government and Regulatory Bodies: We may disclose information to government agencies, regulatory bodies, and law enforcement officials when required, for example, for tax purposes or to report suspicious transactions.
With Your Consent: We may share information with other third parties when you consent or as directed by you or your broker-dealer, such as when you request personalized performance reporting.
Legal Compliance and Fraud Prevention: We may disclose information to other organizations as permitted or required by law, for purposes such as fraud prevention or in response to a subpoena.
Business Transactions: In the event of corporate business transactions, such as a merger or sale of a business, personal information may be shared in connection with the transaction.

Our service providers are legally bound to keep your personal information confidential and are authorized to use it only for the specific services we contract them to perform.

National Financial Services LLC and Your Digital Privacy

When you interact with National Financial Services LLC through our websites, online services, or applications (including mobile apps) that we own and control – collectively referred to as “our digital offerings” – or via electronic communications, we manage your personal information according to all the practices and safeguards detailed in this policy.

When you use our digital offerings or communicate with us electronically, we (or our service providers acting on our behalf) may automatically collect technical, navigational, and location information. This may include your device type, browser type, internet protocol (IP) address, pages visited, and the duration of your visits to our digital offerings. We use this information to enhance the security of your online sessions, streamline site navigation, improve the design and functionality of our digital offerings and electronic communications, and personalize your online experience.

Furthermore, the following policies and practices are specifically applicable when you are online:

Cookies and Similar Technologies

National Financial Services LLC and our third-party service providers utilize cookies and similar technologies (“cookies”) to ensure the smooth operation and maintenance of our digital offerings. Cookies are small data files exchanged between a website or online service and a web browser or application on a visitor’s device (computer, tablet, or mobile phone). Cookies help us gather information about users of our digital offerings, including visit dates and times, pages viewed, time spent on our digital offerings, and general information about the devices used to access them. We also use cookies for security purposes and to personalize your experience, such as remembering your screen layout preferences.

We and our third-party service providers may also employ cookies and other technologies, such as web beacons, pixel tags, or mobile device IDs, in online advertising, as described below. Most web browsers and mobile devices provide settings to manage cookies. However, if you choose to refuse or delete cookies using these settings, it may negatively impact your experience with our digital offerings. Some features and services may not function correctly, and you may be unable to sign in to your account, or we may not be able to recognize you, your device, or your online preferences. Depending on your device and operating system, you may not be able to block or delete all cookies.

We may also collect analytics data or use third-party analytics tools like Google Analytics to analyze traffic and usage trends for our digital offerings and to better understand the demographics of our users. For more information about Google’s privacy practices related to Google Analytics, please visit Google’s Privacy Policy. You can also explore Google’s available opt-out options.

Connecting with National Financial Services LLC on Social Media

National Financial Services LLC engages with customers on social media platforms to facilitate online sharing and collaboration among registered users. When you interact with us through social media, we may collect information you provide, such as photos, opinions, or your social media account ID. Any content you post, including pictures, information, opinions, or personal information shared with other participants on these social media platforms, is governed by the terms of use and privacy policies of those specific platforms. We encourage you to review these policies to understand your rights and obligations regarding such content.

Third-Party Websites, Services, and Content

Our digital offerings may include links to third-party websites and online services (e.g., social media platforms) and embedded content hosted by third parties. This privacy policy does not extend to the privacy practices, security measures, cookie policies, or settings of these third parties. We are not responsible for the privacy practices or content of these external websites, online services, or content providers. When you use a link to access another website or online service or view third-party content (such as an embedded video), please consult the privacy policy of that website or online service for detailed information about their privacy practices and advertising opt-out options.

Children’s Privacy

Generally, National Financial Services LLC’s digital offerings are not intended for individuals under the age of thirteen (13). We do not knowingly collect personal information online from children under 13, and we request that they do not provide personal information through our digital offerings. If we offer a digital offering specifically designed for use by individuals under 13, it will be governed by a separate, dedicated privacy policy.

Information for Former Customers

This privacy policy remains applicable even if you are a former customer of National Financial Services LLC. We treat your information with the same level of care and protection as we do for our current customers.

If you are a customer of a broker-dealer that utilizes NFS services, you can access and correct your account information through various means offered by your broker-dealer and National Financial Services LLC, such as online services. For specific details on how to correct your account information, please contact your broker-dealer directly.

Additional Information for California Residents

This section is specifically for California residents and addresses the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”). It applies to personal information and your relationship(s) with Fidelity Institutional Companies that fall under the scope of the CCPA. In this section, “personal information” is defined as it is in the CCPA and excludes information exempt from the CCPA.

CCPA and Fidelity Institutional Companies

Depending on the Fidelity Institutional Company you interact with, the nature of your relationship, and the products and services provided, some or all of the personal information collected by Fidelity Institutional Companies may be exempt from the CCPA. These exemptions are detailed below (see “CCPA Exemptions”). Therefore, in certain situations, a Fidelity Institutional Company may not be obligated to fulfill CCPA requests, or specific requests may not be honored due to the nature of the personal information involved. Examples of CCPA exemptions include:

If your relationship with a Fidelity Institutional Company is solely for personal financial services (e.g., personal brokerage accounts), your personal information is subject to the federal Gramm-Leach-Bliley Act (“GLBA”). In such cases, Fidelity Institutional Companies are not obligated to honor CCPA requests.
If you are a customer of a broker-dealer that uses NFS services, CCPA requests should be directed to your broker-dealer, not National Financial Services LLC directly.

Your Rights Under the CCPA

The CCPA grants specific rights to California residents and imposes obligations on businesses subject to the CCPA. Below is a description of these general rights. Please note that based on your relationship with Fidelity Institutional Companies, some of these rights may not apply to you. In this context, “consumer” refers to a California resident, and “covered business” refers to a business subject to the CCPA.

Right to Know/Right to Access: You have the right to request disclosure of the categories and specific pieces of personal information a covered business has collected about you. You can also request information about:
1. The categories of personal information collected.
2. The categories of sources from which the personal information is collected.
3. The business or commercial purpose for collecting, selling, or sharing personal information (if applicable).
4. The categories of third parties to whom personal information is disclosed.
5. The specific pieces of personal information collected about you.
These disclosures are not required to include information about activities before January 1, 2022. Also, a covered business is not required to fulfill more than two Right to Know requests from the same consumer within a 12-month period.
Right to Delete: You have the right to request the deletion of your personal information collected by a covered business, subject to certain exceptions.
Right to Correct: You have the right to request correction of inaccurate personal information maintained by a covered business.
Right to Opt-Out of Sale/Sharing: If a covered business sells or shares personal information, you have the right to opt out of the sale or sharing of your personal information.
Right to Limit Use and Disclosure of Sensitive Personal Information: If a covered business uses or discloses sensitive personal information beyond CCPA-defined purposes, you have the right to limit the use or disclosure of your sensitive personal information.
Non-Discrimination: A covered business cannot discriminate against you for exercising your CCPA rights.

Categories of Personal Information We May Collect

Personal identifiers (e.g., name, address, email, IP address, account name).
Information covered by California’s records destruction law (e.g., signature, phone number, financial account information).
Characteristics of protected classifications under California or U.S. federal law (e.g., gender).
Commercial information (e.g., purchase history, services considered).
Internet/electronic network activity (e.g., browsing history, interactions with our digital offerings).
Audio, electronic, visual, and similar data (e.g., call recordings).
Inferences drawn to create a profile about you (e.g., preferences, behavior).
Sensitive personal information (e.g., Social Security number, account login credentials).

Data retention periods vary based on data type, purpose of collection and use, operational needs, legal and regulatory requirements, security needs, and business continuity requirements.

Categories of Sources of Personal Information

In addition to sources mentioned earlier (“How and why we obtain personal information”), we may collect personal information from:

You or your representative (e.g., interactions with our services or digital offerings).
Your broker-dealer, investment professional, and other financial services firms.
Publicly available information sources.
Referrals from people who know you.
Third parties providing products or services through your relationship with us.
Third parties performing services for us.
Other third-party sources (e.g., government sources, data brokers, social networks).
Automatically, via cookies and web beacons, when you interact with our digital offerings.

Why We Collect Personal Information

Please refer to “How and why we obtain and use personal information” for business and commercial purposes of data collection. Additional purposes include:

Providing information about products and services of interest.
Maintaining record accuracy and integrity.
Marketing and communications.
Reporting and analytics.
Personalizing interactions and experiences.
Training and quality control.
Identity verification.
Protection against fraud and illegal activity.
Business analysis, planning, and reporting.
Customer education.
Effectiveness measurement.

Categories of Personal Information Disclosed for Business Purposes

Like most businesses, we disclose personal information to third parties for business purposes. Depending on your relationship and interactions with us, this may include categories of personal information listed under “Categories of personal information we may collect about you” and categories of third parties listed under “Categories of sources of which personal information is collected“.

Selling/Sharing of Personal Information

National Financial Services LLC does NOT sell your personal information for monetary or other compensation. However, certain information sharing practices on our websites may be considered a “sale” or “sharing” under the CCPA, specifically for “cross-context behavioral advertising.”

We use third-party providers (marketing, advertising, social media) to personalize your website experience, deliver targeted ads, and measure website and ad effectiveness. These providers may collect data about your website activity via cookies and similar technologies, and may combine it with data from other websites to show you our ads elsewhere. This sharing of information via cookies may be considered a “sale” or “sharing” under the CCPA.

California residents have the right to opt out of this “sale” or “sharing.” On websites where these activities occur, California visitors will see a “Do Not Sell or Share my Personal Information” link in the website footer. Click this link and follow the prompts to opt out.

Fidelity also supports the Global Privacy Control (GPC) signal. If you have GPC enabled in your browser, we will automatically honor your opt-out request. Opt-out settings are browser and device-specific; you must opt out separately on each browser and device.

In the 12 months prior to this notice, we have engaged in activities that may be considered “selling” or “sharing” personal information for “cross-context behavioral advertising” for California residents. We do not knowingly “sell” or “share” personal information of minors under 16.

CCPA Exemptions

Certain personal information types are exempt from the CCPA. Covered businesses have limited or no CCPA obligations regarding:

Information under the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act.
Medical information under the Confidentiality of Medical Information Act or protected health information under HIPAA.

Additionally, some businesses are exempt from the CCPA, including:

Businesses not operating in California.
Non-profit organizations.
Businesses not controlling the processing of personal information.
Businesses with annual gross revenue of $25 million or less.

Under the CCPA, a covered business may refuse to delete personal information in certain situations, including when retention is necessary to:

Complete a transaction or provide a requested service.
Ensure security and integrity.
Exercise free speech or another legal right.
Debug errors.
Enable internal uses aligned with consumer expectations.
Comply with legal obligations.

This CCPA description is a summary and not a complete legal description. The CCPA includes further exemptions and situations where deletion requests may be refused.

Submitting a CCPA Request

To submit a CCPA request to Fidelity Institutional Companies, please use the options on our California Privacy Rights Request Page. Before submitting, review all CCPA exemptions, including those listed under “CCPA Exemptions.”

Important: If you are a customer of a broker-dealer using NFS services, direct CCPA requests to your broker-dealer.

You should receive a response within 45 days, with a possible 45-day extension if needed, with notification.

We will need to verify your identity before processing your request. The request process will outline required information for verification. You may need to confirm California residency and verify your identity or the identity of authorized agents.

Information provided will be used for identity verification. For details on authorized agents for CCPA requests, please refer to our page. Fidelity Institutional received 1 CCPA request for disclosure and 2 requests for deletion between January 1, 2023, and December 31, 2023.

This privacy policy is reviewed annually and updated accordingly.