Our commitment to your privacy: Direct Capital Securities, Inc. (“DCS”) has a policy of protecting the confidentially and security of information we collect about our customers.

This Privacy Notice (the “Notice”) is addressed to United States customers (“you”) of DCS. The Notice explains how we collect and safeguard information about you and how to tell us your “opt out” choices. In this Notice, DCS may be interchangeably referred to as “us”, “we”, and “our”.

What Information Do We Collect?

We obtain information about you from a variety of sources. Mainly, you provide us with information about yourself, such as your name, address, social security number, income and asset information.

Other sources, such as credit reporting bureaus and/or other parties in possession of non-public information about you, furnish us with additional information about your credit history, assets, and criminal records and civil litigation. This information is collectively referred to as “Customer Information”.

What Do We Do with the Customer Information?

Mainly, we use the Customer Information in connection with suitability standards. This means that as we collect your information, we share and verify it with any affiliates and/or companies and individuals we work with. These include lending institutions, sponsors, broker dealers, escrow companies, attorneys and other parties involved in our transactions. Furthermore, we may disclose Customer Information to other third parties as permitted by law. This may include responding to subpoenas, credit reporting agencies, outside parties requesting verifications, or simply in an effort to prevent fraud and protect your information.

Your Opt Out Choices

You have ‘opt out’ choices about the handling of your Customer Information. You may also opt out from certain offers that may be sent to you and how these offers may be delivered to you. These opt out choices are explained directly below.

How to Opt Out

You may opt out from receiving offers or simply ask for clarifications about this Notice and DCS’ policy in various ways. You may contact us directly at 310-566-4503, or simply by emailing us at compliance@1031market.com.

This Privacy Statement (the “Policy”) covers TIC Capital Markets, Inc. (the Parent Company) and Direct Capital Securities, Inc. (the subsidiary). These entities are collectively referred to as “we”, “us”, and “our” throughout this statement.

We are committed to protecting our customers’ personal and financial information. In the course of providing you with financial products and services, we need to collect and maintain certain nonpublic personal information about you. This Policy addresses some questions about what public and nonpublic personal information we collect, what we do with it, and how we protect it.

What types of nonpublic personal information do we collect?

If you are a direct customer of ours¹, we collect various information: information provided by you on our forms or applications, such as your name, address, social security number, date of birth, employment information, investment experience, risk tolerance, information about your finances and assets; information about you from consumer reporting agencies, such as your credit history and worthiness, prior and current criminal history, if any, and litigation or judicial matters involving you.

To what kind of entities do we disclose nonpublic personal information?

We may disclose nonpublic personal information about you that we collect, primarily to make available to you the financial products that we and our business partners provide. We do not provide nonpublic personal information about former customers to anyone, except as permitted and required by law.

To what types of entities (other than those companies used to process or service transactions) do we disclose nonpublic personal information?

We may disclose certain information about you to our affiliated companies and to other financial services providers with which we have a joint marketing agreement or that offer financial products and services with us or on our behalf. By sharing information about you and your accounts, transactions, and other customer relationships without affiliated companies and other financial providers, we can provide you with a broader range of financial products and services, improve your experience with us, and better serve your financial needs.

We may also disclose information that we collect from you such as your name, contact information, and customer relationships with us to nonaffiliated third parties that perform services, such as marketing or market research, on our behalf. For example, we may provided your name, address, phone number, and/or email address to vendors who send our email or regular mail. Of course we require these companies or entities to keep your information confidential. We also prohibit them from using or disclosing your information except for the limited purpose and to the persons for whom disclosure was intended, or as otherwise permitted by law.

¹A direct customer is, for our purposes, one that enters into a transaction with Direct Capital Securities, Inc. through a registered representative duly registered at the firm.

It is important that you know that we do not sell your personal information to third-party marketers or any other entity for any purpose.

To what other types of entities might we disclose nonpublic personal information?

We do not disclose nonpublic personal information to other parties or individuals, except as follows: we disclose such information to nonaffiliated third parties as permitted or required by law. These parties include government/regulatory organizations, such as the Internal Revenue Service (IRS), the Securities and Exchange Commission (SEC), the Financial Industry Regulatory Authority (FINRA) and to parties under a court order or subpoena that request this information. Disclosures for which you have provided your consent or you have directed us to make are also permitted.

What ‘opt-out’ options are available and how can they be exercised?

The law allows you to ‘opt-out’ of sharing nonpublic personal information about you in certain circumstances with affiliated and nonaffiliated companies. You may direct us not to make such disclosures by contacting us as noted on our Privacy Policy Notice, sent to customers on an annual basis.

How do we protect the confidentiality and security of nonpublic personal information?

We maintain physical, electronic, and procedural safeguards that meet industry standards to guard your nonpublic persona information. Our employees (registered representatives, operations support, compliance, legal and supervisory personnel) have access to your nonpublic persona information only on a need-to-know basis. Our Principal and President conduct regular internal audits of our business practices and procedures, examining confidentiality standards and information access in order to protect your personal information.

What about ‘cookies’?

‘Cookies’ are small amounts of data that a web site can send to your web browser and store on your computer. Cookies do not contain personal information about you (unless you knowingly provide it). Cookies can note that your browser was used to visit certain sites, pages, or advertisements on a certain date.

We use cookies to enhance navigation and functionality of our web site, to verify your identity, and to personalize aspects of your experience on our site. We also use cookies to let us know how visitors are using our web site so that we can improve our site and your experience on it.

It is important to note that you have control over cookies. Most browsers can be set to notify you when a cookie is being placed on your computer. You can set the browser to refuse or accept cookies, although this may affect or limit your internet experience.

How to access and update your nonpublic personal information:

We take certain measures to ensure that your nonpublic personal information is accurate and up-to-date, but this depends largely on information provided by you. To assist in this process, you should contact us to provide updated information or advise us about any changes in your financial life or any major changes in your personal and/or business affairs.