Information is essential to maintain our ability to provide superior service. Our most important asset, however, is maintaining the trust of our customers. A commitment to keep customer information secure is a top priority for all of us at Firefly Capital, Inc. This privacy statement will disclose the manner in which Firefly Capital, Inc will handle the personal information about you that is collected and the extent to which it may be disclosed.

The following provisions articulate our privacy commitment to our former customers as well as current customers unless we state otherwise:

1. We will safeguard, according to strict standards of security and confidentiality, any information our customers share with us. Firefly Capital, Inc will protect your personal information by using appropriate security safeguards. We will remain alert and prepared to adapt these measures to address potential threats, hazards or unauthorized access. You can take added steps to increase your security online and protect your confidential information by minimizing the use of e-mail to transmit confidential information regarding your account. You are solely responsible for maintaining the confidentiality of all passwords and usernames used to access your online trading and related e-mail account.
2. We will limit the collection and use of customer information to the minimum required to deliver superior service to our customers. This may include, but is not limited to, information provided to us by the customer during the new account opening process as required by our regulators, the customer's transactional history, information from credit checks and from cookies, and any information required to adequately administer our services to the customer.
3. We will permit only authorized employees, who are trained in the proper handling of customer information, to have access to that information. Employees who violate our privacy policy will be subject to our normal disciplinary process.
4. We will not reveal customer information to any external organization unless: a) we have been authorized by the customer explicitly or implicitly; b) the customer was informed by previous disclosures or agreements; c) the external organization is an affiliated or associated service provider necessary for the conduct of our business; or d) we are required to do so by law or by our regulators.
5. We will always maintain control over the confidentiality of our customer information. Whenever we hire other organizations to provide support services, we will require them to conform to our privacy standards. For purposes of credit reporting, verification of identity and risk management, we may exchange information about our customers with reputable credit-reporting agencies, clearinghouse agencies, and routine business needs. We will impose contractual commitments and procedures that require our service providers to adhere to privacy and security policies consistent with our own. We may also facilitate relevant offers from reputable companies. These companies are not permitted to retain any customer information unless the customer has specifically expressed interest in their products or services.
6. Occasionally, Firefly Capital, Inc will use e-mail and direct mailings to inform you of new product and enhanced service offerings that we deem to be of relevance to our customers. At any time, customers may contact a Firefly Capital, Inc registered representative if they wish to remove their names from such lists.
7. We will attempt to keep customer files complete, current, and accurate. Customers may call a registered representative at (617) 314.0705 or (888) 883.3359 to update or correct any account related information.