Why We Collect and How We Use Information: We limit the collection and use of Information to the minimum we require to deliver and improve service to you. Such service includes processing transactions for services we provide, providing you with software analysis tools (and related educational, training and support), and administering our business.
How We Gather Information: We get most Information directly from you, when you apply for, access and use our products and services—whether in person, by telephone or electronically. We may verify this information or get additional information from consumer or investigative reporting agencies or public sources. This Information may relate to your transactions and interaction with our technology, products and services. The personal information we collect may include your name, address, telephone number, email address, or any additional information related to validating your identity for security purposes. In addition, Web tools are used on our Web site to help us monitor traffic patterns and to see how the user navigates through our site. These Web tools are used by us and our affiliates for internal purposes only and are not used to collect or disseminate personal information to any third party.
Disclosure of Information: We do not disclose any nonpublic information about our customers or former customers to anyone, except as required by law. Information may be disclosed for audit or research purposes, to attorneys or other professionals, or to law enforcement and regulatory agencies, for example, to help us prevent fraud. In addition, we may disclose Information to affiliated and non-affiliated third party service providers (i) to enable them to provide business services for us or our securities affiliate’s clearing firm(s), such as performing computer related or data maintenance or processing services. Except in those specific, limited situations, without your consent we will not make any disclosures of Information to other companies who may want to sell their products or services to you. For example, we do not sell customer lists and we will not sell your name to a catalogue company. It is Lucena’s policy to require all third parties that are to receive any Information, other than our securities affiliate’s clearing firm(s), to sign strict confidentiality agreements.
Non Affiliates: Current law allows you to limit the sharing of Information with nonaffiliated third parties under certain circumstances. Since we do not currently share your Information with nonaffiliated third parties, other than as described in this policy, there is no need for you to opt-out.
Access to and Correction of Information: If you desire to review any file we may maintain for your personal Information, please contact us. If you notify us that any Information is incorrect, we will review it. If we agree, we will correct our records. If we do not agree, you may submit a short statement of dispute, which we will include in future disclosures of the disputed Information. Information collected in connection with, or in anticipation of, any claim or legal proceeding will not be made available.