The Securities and Exchange Commission recently enacted Regulation S-P, the customer privacy rule. Themis Trading LLC (“Themis”) and its employees understand that privacy is an important issue for its customers. It is our policy to respect the privacy of all customers and accounts that we maintain as introducing broker, and to protect the security and confidentiality of related non-public personal information. Please note that this policy applies to current and former customers.

Personal/Private Information Collections

Themis introduces accounts on a fully disclosed basis to Themis’ clearing broker, Pershing LLC. In order to service introduced accounts and provide other financial services that customers have requested (i.e. commission sharing arrangements), Themis collects information and provides it to its clearing broker and other required parties. The information may come from the following sources:

• information received from customers, such as customer name, address, telephone number, social security number, tax ID number, occupation and income;
• information relating to trading and clearing in connection with customer transactions, including account balances, positions and allocations;
• information which may be received from consumer reporting agencies, customer vendors and the government, such as credit bureau and other information relating to your creditworthiness or reports obtained while conducting our AML obligations; and
• information which may be received from other sources with customer consent or with the consent of customer clearing brokers.

Sharing of Nonpublic Information

Themis does not disclose non-public personal information relating to current or former customers to any third parties, except as required or permitted by law and in order to facilitate the clearing of customer transactions or other financial services requested by customers in the ordinary course of business.

Security

Themis strives to ensure that our systems are secure and that they meet industry standards. We protect personal information by maintaining physical, electronic and procedural safeguards that either meet or exceed applicable law. Where appropriate, we employ firewalls, encryption technology, user authentication systems (i.e. passwords and personal identification numbers) and access control mechanisms to control access to systems and data. Third parties who have access to such personal information must also agree to follow appropriate standards of security and confidentiality.

Opt-out Policy

If you prefer that we do not share your information (other than as prescribed by law) with non-affiliated third parties, you may contact our Compliance Department at 973-665-9600 or pzajac@ThemisTrading.com.