CLEARTRADE COMMODITIES WEBSITE POLICY

CLEARTRADE WEBSITE PRIVACY STATEMENT

At ClearTrade maintaining trust and confidence is a high priority. We understand that privacy is an important issue for our valued clients, as well as visitors to our websites. Whether you are a client of ClearTrade, or a visitor browsing our websites, we want you to understand how we work to protect your privacy in the event we collect and use information about you, and the steps we take to safeguard that information.

GENERAL INFORMATION ABOUT BROWSING CLEARTRADES WEBSITES

At ClearTrade, no account or personal information is retrieved from ClearTrades servers when a client or visitor browses the public (pre-login) areas of our websites. Although ClearTrade uses website data to improve the content and services offered to its website visitors, such data is reported on an aggregate, anonymous basis, and we associate no personal information with such gathering of data. Such data may include: how many people visit our websites; the pages they visit; how long they stay on our websites; and the domain name of the site visitors connect from (e.g., yahoo.com).

A WORD ABOUT COOKIES

Cookies are small text files that a website transfers to your hard drive or browser to help you move faster through that particular website, or for tracking your website usage. ClearTrade does not use cookies to gather personal information such as a person's name or email address. We do, however, use cookies to identify repeat visitors to our websites, to determine the path visitors take to our websites, and to identify visitors who came to ClearTrade websites as a result of a banner ad on a third party website. Please be assured that any information we gather by the use of a cookie is compiled on an aggregate, anonymous basis. Although your browser might allow you to 'reject' cookies, we require that you accept all cookies in order for our websites' features and security mechanisms to function fully.

Third parties might also create cookies when you access their sites through links posted on our sites. We do not have access to these cookies or any information that these cookies may contain. Please contact the third party site for more information on their policies regarding cookies. Although we expect third parties to adhere to our privacy policies and terms and conditions of use, we are not responsible for the actions or policies of such third parties.

A WORD ABOUT HYPERLINKS

ClearTrades websites may contain hyperlinks or 'links' to other sites, and other sites may 'link' to our sites. Websites linking to and from our sites may have privacy practices different from ClearTrades. This Website Privacy Statement applies solely to information collected by our websites. ClearTrade is not responsible for the privacy policies or the content of sites you link to, and we have no control over the use or protection of information provided by you or collected by those sites. If you elect to link to a co-branded website or to a linked website, you may be asked to provide registration or other information. Please note that the information you are providing is going to a third party, and you should familiarize yourself with the privacy policy provided by that third party.

NONPUBLIC PERSONAL INFORMATION

In the event visitors provide ClearTrade with nonpublic personal information about themselves (e.g., name, address, phone number, email address) for the purpose of receiving information about our products and services, or if you are a ClearTrade client and we obtain from you or from other sources nonpublic personal information about you in the course of providing you with our products and services, the following are the steps we take to safeguard such nonpublic personal information ('Personal Information').

SECURITY PROCEDURES:

ClearTrade restricts access to Personal Information about you to:

Those of our employees and affiliates who need to know that information in order to provide the products and services you receive from us.

Those unaffiliated third parties whose access to such information is permitted or required by law and who need to know that information in order to assist us in providing you with the products and services you receive from us.

INFORMATION WE COLLECT:

In providing you with financial products and services, or information about such services, ClearTrade may collect the following types of Personal Information:

Information we receive from you on account applications, whether written or electronic, or on other forms (including on-line forms). This information would include your name, address, social security number, income, investment experience, and so forth.

Information about your transactions with us, our affiliates, or others. This information could include your trading through us, our affiliates and others, your history of meeting margin calls, and your use of the various products and services that we and our affiliates provide.

Information about your creditworthiness, credit history, and other information about you that we receive from consumer reporting agencies, our affiliates, or providers of other demographic information, such as your purchasing or investment preferences.

Information about you obtained in connection with our efforts to protect against fraud or unauthorized use of your account(s) with us.

CATEGORIES OF PARTIES TO WHICH WE MAY DISCLOSE:

ClearTrade may disclose the types of Personal Information listed above (see INFORMATION WE COLLECT) to the following types of third parties:

We may also disclose Personal Information to other nonaffiliated third parties as permitted or required by law, such as in response to a subpoena or legal process or in order to complete a transaction which you initiated and authorized.

WEBSITE PRIVACY STATEMENT UPDATES

ClearTrade may, from time to time, make changes to this Website Privacy Statement. We recommend that frequent visitors to our websites reread this Website Privacy Statement periodically to learn of any updates and changes we have made to this Statement.

RIGHT TO OPT OUT OF INFORMATION SHARING:

If you prefer that we not disclose your Personal Information to unaffiliated third parties, you may opt out of those disclosures. That is, you may direct us not to make those disclosures (other than disclosures permitted or required by law). You, however, may not opt out of Personal Information disclosed about you to your Introducing Broker (if applicable), or any service provider necessary to effect or process any transaction in your account(s) with us (if applicable). If you wish to opt out of disclosure to nonaffiliated third parties, you may email us at cleartrade@rcn.com, stating that you wish to opt out of all information sharing of your Personal Information.

JOINT ACCOUNT/PARNERSHIP PROCEDURES:

In the event you have a ClearTrade account, and if your account(s) with us is for joint tenants with rights of survivorship, tenants in common, or a general partnership, any one party to the account may elect to opt out for the account. That opt out election will bind all parties to the account.

ONLINE SERVICES:

If you register for our online products or services, we retain your user ID and password and other information about your use of our websites in order that we may recognize you as a registered user. We may obtain your email address from you or from another source.

If you opt out from receiving email offers, we may still send (via email or otherwise) important information about your account(s) with us (if applicable) and our products and services.