• Information you provide to us on applications and other forms, such as your name, address, date of birth, social security number, occupation, assets, and income.
• Information about your transactions with us and with our affiliates.
• Information we receive from consumer reporting agencies, such as your credit history and creditworthiness, and other entities not affiliated with the KDM Trading, Inc.
• Information you provide us to verify your identity, such as a driver’s license or information we receive from other entities not affiliated with KDM Trading, Inc.
• Information collected on customer visits to KDM Trading, Inc.’s web site.  If you elect to use our online products or services, KDM Trading, Inc. allows you to register and create your own unique user ID and password, so that KDM Trading, Inc. may recognize you as a registered user.  KDM Trading, Inc. may collect information about your visits to our web site through that ID and password.

How we protect personal information

• We do not share, sell or rent your personal information to anyone.
• We limit access to your personal information to those employees or independent contractors who need to know in order to conduct business, service your account, help provide you with products and services, help us improve our services to you, and to inform you about additional products or services that may be of interest to you.
• We require that our employees, independent contractors and clearing affiliate’s maintain and protect the confidentiality of your personal information.  For example, except for information sent directly from us, you should not receive any marketing solicitations, product advertisements, solicitor phone calls, or any solicitations from other brokers or organizations as a result of establishing a relationship with us.
• We maintain physical, electronic, and procedural safeguards to protect your personal information.

Sharing information with our affiliates and clearing firm

We may share personal information described above with our affiliates and futures clearing firm for business purposes, such as servicing customer accounts and informing customers about new products and services, and as permitted by applicable law.  The information we share with affiliates may include the information described above, such as name, address and MF Global account information, but will not include other credit information, such as credit history appearing on a consumer credit report or net worth and income information appearing on applications for our products and services.

Disclosure to Non-Affiliated Third Parties

In order to support the financial products and services we provide to you, we may share the personal information described above with third-party service providers not affiliated with us, including companies under contract to perform services for us or on our behalf, such as vendors that prepare and mail information to you, provide data processing, computer software maintenance and development, transaction processing and marketing services and other services that are considered necessary in order for us continue operating our business as well as adhering to the rules and regulations that govern our business.

These companies acting on our behalf are required to keep your personal information confidential.

Also, we may disclose personal information with non-affiliated companies and regulatory authorities as permitted or required by applicable law.  For example, we may disclose personal information to cooperate with regulatory authorities and law enforcement agencies to comply with subpoenas or other official requests, and as necessary to protect our rights or property.  Except as described in this privacy policy, we will not use your personal information for any other purpose unless we describe how such information will be used at the time you disclose it to us or we obtain your permission to do so.

Accessing and revisiting your personal information

We endeavor to keep our customer files complete and accurate.  We will give you reasonable access to the information we have about you.  Most of this information is contained in account statements that you receive from us and applications that you submit to obtain our products and services.  We encourage you to review this information and notify us if you believe any information should be corrected or updated.  If you have a question or concern about your personal information or this privacy notice, please contact KDM Trading, Inc.

Non-personally identifiable information collected

KDM Trading, Inc. collects certain non-personally identifiable information, such as the:

• address of the web site you came from
• name of the domain used to access the Internet
• type of browser used
• date and time of the visit
• pages visited