Information Collected by CMS

The categories of nonpublic personal information which CMS shall collect include:

  1. information provided by the customer when opening an account, or to process a transaction, such as name, address, assets, bank information, prior trading experience, etc.;
  2. information used to verify the identity of the customer, including copies of government issued identification materials such as passports, drivers licenses, and credit reports;
  3. information resulting from transactions between the customer and CMS or an affiliate of CMS, such as withdrawal and deposit forms;
  4. information derived from customer’s navigation and usage of CMS’s website and online platforms, including account trading statements;

Information Disclosed by CMS and To Whom CMS Discloses the Information

CMS does not share nonpublic personal information about our clients or former customers to anyone, except as permitted by law.

For example, CMS may provide information to non-affiliated third parties, as permitted by law, in providing financial services to you. This includes a consumer reporting agency that prepares your credit report.

Furthermore, CMS may provide information, as permitted by law, to government or regulatory agencies and to comply with a legal summons, court order, subpoena or a similar legal process, audit or investigation.

We may also disclose your nonpublic personal information if you authorize such disclosure.

Confidentiality and Security Procedures

Only those personnel for whom the information is necessary to complete a given transaction shall possess the authority to access the information. CMS, its personnel, and its affiliates shall strictly adhere to security practices and procedures to ensure the confidentiality of its customers’ information.

CMS maintains numerous safeguards that comply with Federal regulations to guard your nonpublic personal information.

CMS will continue to protect the privacy of former customers’ nonpublic personal information in the same manner as when they were customers. Unlike continuing customers, however, former customers will not receive annual privacy notices.

CMS will provide a notice of our privacy policy annually, as long as the customer maintains an account with CMS. CMS reserves the right to make changes to this policy. This policy may always be reviewed on