Privacy Policy

Cuatro Capital Securities, LLC Privacy Policy

Cuatro Capital Securities, LLC (“CCS”), a broker-dealer registered with the U.S. Securities and Exchange Commission (“SEC”), a member of the Financial Industry Regulatory Authority, Inc. (“FINRA”), and the Securities Investor Protection Corporation (“SIPC”), provides various trading and investment advisory services to retail and institutional investors (the “Services”).

CCS understands that confidentiality and security of the personal information (“Personal Information”) that you share with it is important. CCS is responsible for the Personal Information that it may collect in the manner discussed below. CCS (which is, at times, referred to using phrases such as “we”, “us” or similar phrases) is committed to protecting the privacy of Personal Information, including Personal Information related to individuals who may be customers, employees, agents, job applicants or others.

In this regard, CCS has developed policies and practices designed to protect the privacy of your Personal Information. By opening an account at CCS or by utilizing the products, Services and applications available through CCS, you have consented to the collection and use of your Personal Information in accordance with this privacy policy (“Privacy Policy”). Please read this Privacy Policy carefully.

This Privacy Policy is based on the privacy and data protection principles common to the countries in which it operates. This Privacy Policy is intended to summarize the CCS’ data protection practices generally and to advise its customers, prospective customers, job applicants, website visitors and other third parties about privacy policies that may be applicable.

This Privacy Policy is specifically addressed to those who provide Personal Information to CCS or who visit or use CCS’ websites, software applications and/or social media sites.

How does CCS collect Personal Information and what Personal Information does CCS collect?

CCS collects and processes Personal Information from you. This may include, among other things, information:

Provided during the account application processes or during use of any CCS website applications (for example, your name, email address, telephone number, birth date, tax ID number, investment objectives, etc.);
Acquired as a result of the transactions you conduct through CCS systems or in connection with services offered by CCS;
Received from consumer-reporting agencies; and collected through Internet cookies (for further information on CCS’ use of cookies, please see the Cookie Policy).

Are you required to provide Personal Information?

In order for you to utilize CCS’ Services, you will provide CCS with your Personal Information entirely voluntarily. In many circumstances, CCS cannot take action without utilizing certain of your Personal Information, for example, because this Personal Information is required to process your instructions or orders or provide you with access to its Services or marketing materials. In many cases, it would be impossible for it to provide the Services to you without the relevant Personal Information.

For what purposes will CCS use your Personal Information?

CCS may use your Personal Information for the following purposes (“Permitted Purposes”):

To provide you with brokerage and other services available on CCS platforms, and/or to deal with any requests or inquiries you may have;
To pursue legitimate interests, including to carry out, monitor and analyze CCS’ business or operations;
To conduct CCS’ recruiting processes;
To contact you (unless you tell us that you prefer us not to) regarding features and functionality that may be of interest to you;
To enter into or carry out contracts of various kinds;
To conduct monitoring by CCS or any other person on its behalf using various methods, including: (i) the use of “intelligent” automated monitoring tools; (ii) through random monitoring of systems, for example systematically via electronic communication recording tools; (iii) specific monitoring of systems for example in relation to investigations, regulatory requests, subject access requests, litigation, arbitration or mediation; (iv) data tracking, aggregation and analysis tools that pull data from various disparate data sources to draw linkages and/or detect behavioral patterns, interactions or preferences for analysis (including predictive analysis); and/or (v) using other similar monitoring technology that may become available from time to time;
To comply with applicable laws or regulations in any country;
To provide third parties information in connection with the proposed or actual financing, insuring, sale, securitization, assignment, or other disposal of all or part of our business (including accounts) for the purposes of evaluating and performing the proposed transaction; and
For any other purpose for which your Personal Information was provided to CCS.

CCS may process your Personal Information for the following purposes after obtaining your express consent where legally required:

To communicate with you through the channels you have approved to keep you up to date on the latest developments, announcements and her information about CCS services, products and technologies;
To conduct client surveys, marketing campaigns, market analysis, or promotional activities; and
To collect information about your preferences to create a user profile to personalize and foster the quality of CCS’ communication and interaction with you (for example, by way of newsletter tracking or website analytics).

Where legally required, with regard to marketing-related communication, CCS will only provide you with such information after you have opted in and it will also provide you with the opportunity to opt out at any time if you do not wish to receive further marketing-related communication from us. CCS likes to keep its clients, personnel and other interested parties, informed of company developments, including news relating to CCS that it believes is of interest to them. If you do not wish to receive publications or details of events or seminars that CCS considers may be of interest to you, please let it know by contacting assistants@cuatromarkets.com. Where legally required, CCS will not use your Personal Information for taking any automated decisions affecting you or creating profiles other than described above.

Depending on which of the above Permitted Purposes CCS uses your Personal Information for, it may process your Personal Information on one or more of the following legal grounds:

Because processing is necessary for the performance of a client instruction or other contract with you or your organization;
To comply with CCS’ legal obligations (for example, to keep pension records or records for tax purposes);
Since processing is necessary for the purposes of CCS’ legitimate interest or those of any third-party recipients that receive your Personal Information, provided that such interests are not overridden by your interests or fundamental rights and freedoms; and
Since processing is useful or necessary in CCS’ discretion and is not prohibited under the law of the relevant jurisdiction.

In addition, the processing may be based on your consent where you have expressly given that to CCS.

Who CCS shares your Personal Information with, and in what circumstances

CCS may share your Personal Information in the following circumstances:

CCS may share your Personal Information with affiliates on a confidential basis as allowed by applicable law or where required for the purpose of providing products or services and for administrative, billing and other business purposes. An affiliate is a company that CCS owns or controls or with which there is common ownership with it and its parent company; CCS may instruct its service providers, domestically or abroad, to process Personal Information for the Permitted Purposes on its behalf and in accordance with its instructions. CCS generally requires these service providers to enter into confidentiality agreements with CCS that limit their use of the information that they receive. Such agreements prohibit the service provider from using CCS’ customer information that they receive other than to carry out the purposes for which the information was disclosed. If required by law, CCS will retain control over and will remain responsible for your Personal Information and will use appropriate safeguards to ensure the integrity and security of your Personal Information when engaging service providers;
CCS may share information with joint marketing partners and alliances that offer products and services that might be a value to CCS’ clients. These offers will require that they be identified that an offer is being extended because of your relationship with CCS. The use of Personal Information is limited to the purposes identified in CCS’ relationship with the partner or alliance;
CCS may share your Personal Information with companies providing services in the areas of fraud and crime prevention and with companies providing similar services, including financial institutions such as credit reference agencies and regulatory bodies;
CCS may share your data with third parties to assist CCS with the conduct of its recruitment processes; Consistent with applicable law, CCS may share your Personal Information with courts, law enforcement authorities, regulators or attorneys or other parties for the establishment, exercise or defense of a legal or equitable claim or for the purposes of a confidential alternative dispute resolution process; and
CCS may also use aggregated Personal Information and statistics for the purpose of monitoring website usage in order to help it develop its website and Services.

Otherwise, CCS will only disclose your Personal Information when you direct it or give it permission to do so, when CCS is allowed or required by applicable law or regulations or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.

SMS Messages

If you provide your mobile number, you consent to receive SMS text messages from CCS related to your account, transactions, and promotional content, as permitted by law. We value your privacy and will not share, sell, rent, or otherwise disclose your mobile number to third parties for their marketing purposes. Message frequency may vary depending on your interactions with us, such as purchases, preferences, and service updates. Message and data rates may apply depending on your mobile carrier and plan and any charges are your responsibility. We only collect the information that is necessary to operate our services and comply with all applicable TCPA regulations and the National Do Not Call Registry. We cooperate with law enforcement and regulators as required; however, we challenge any overbroad requests for user data and notify users of any legal process, giving you the chance to defend your rights. Your consent to receive SMS messages is not a condition of purchasing any goods or services from us.

Depending on your state of residence, you may have additional privacy rights under applicable state laws. To exercise any of these rights, you may contact us at assistants@cuatromarkets.com. We will verify your identity and respond as required under applicable law. If you are a resident of California, Colorado, Connecticut, Utah, Virginia, or other states with comprehensive consumer privacy laws, please contact us for information about how to exercise these privacy rights. You may opt out of receiving SMS messages at any time by replying STOP to any message you receive from us. For assistance contact our customer support team at assistants@cuatromarkets.com.

Personal Information about other people that you provide to CCS

If you provide Personal Information to us about someone else (such as one of your directors or employees or someone with whom you have business dealings), you must ensure that you are entitled to disclose that Personal Information to us and that, without CCS taking any further steps, CCS may collect, use and disclose that Personal Information as described in this Privacy Policy. In particular, you must ensure that the individual concerned is aware of the various matters detailed in this Privacy Policy, as those matters relate to that individual, including CCS’ identity, how to contact CCS, its purposes of collection, CCS’ Personal Information disclosure practices (including disclosure to overseas recipients), any right the individual may have to obtain access to the Personal Information and make complaints about the handling of the Personal Information and the consequences if the Personal Information is not provided (such as CCS’ inability to provide the Services).

Keeping Personal Information about you secure

To the extent required by law, CCS will take appropriate technical and organizational measures to keep your Personal Information confidential and secure in accordance with CCS’ internal procedures covering the storage, disclosure of and access to Personal Information. Personal Information may be kept on CCS’ information technology systems, those of its service providers or in paper files.

Updating your Personal Information

If any of the Personal Information that you have provided to us changes, for example if you change your email address or if you wish to cancel any request that you have made of us, please let us know by contacting CCS Customer Support at assistants@cuatromarkets.com. CCS will not be responsible for any losses arising from any inaccurate or incomplete Personal Information that you provide to us.

How Long Do We Retain Your Personal Information?

CCS retains your Personal Information in an identifiable form in accordance with CCS’ internal policies which establish general standards and procedures regarding the retention, handling and disposition of your Personal Information. Personal Information is retained for as long as necessary to meet legal, regulatory and business requirements. Retention periods may be extended if CCS is required to preserve your Personal Information in connection with litigation, investigations and proceedings or it may be retained for other reasons.

Notice to California Residents: Subject to certain exceptions and limitations, you have the following rights with respect to covered personal information.

You have the right to request the following information from us.
- Specific pieces of personal information CCS has about you;
- Categories of personal information CCS has collected about you;
- Categories of sources from which the personal information is collected;
- Categories of personal information sold or disclosed, if any;
- Categories of third parties with whom the personal information was sold or disclosed; and
- The purpose(s) for collecting or selling the personal information.
You have the right to request that CCS delete the personal information it has collected about you.
You have the right to request to be opted out from the sale of your personal information.
In certain circumstances, you may have the right to receive personal information concerning you in a portable format.
You have the right not to be denied goods or services, charged different prices or rates for goods or services, or receive a differing level of quality of goods or services as a result of exercising the above rights.

The rights described above do not apply to certain categories of personal information. The personal information excluded from coverage under the California Consumer Privacy Act (“CCPA”) includes, among other things:

Personal information CCS collected from or about you when you apply for or obtain a product or service for personal, family or household purposes;
Personal information about communications or transactions with you when you are acting on behalf of a company or government agency to do business with CCS; and
Personal information sold or bought from a consumer reporting agency for use in a consumer report in compliance with applicable law.

CCS will apply verifiable consumer requests to covered personal information. You or your authorized agent may submit a CCPA request via email at assistants@cuatromarkets.com CCS will respond to authorized requests as soon as practicable and as required by law. The above rights are subject to CCS’ ability to reasonably verify your identity and authority to make these requests. In order to verify that you are authorized to submit a request, you may be required to provide the following information.

Your CCPA rights are subject to various exclusions and exceptions under the law. Under certain circumstances, CCS may be unable to implement your request, pursuant to applicable law. CCS will advise you of any reason for denying or restricting a request to the extent permitted by law.

CCS will not provide social security numbers, driver’s license numbers or government issued identification numbers, financial account numbers, health insurance or medical identification numbers, account passwords or security questions and answers, or other specific pieces of personal information if the disclosure presents an unreasonable risk to the security of personal information, customer accounts or CCS’ systems and network security.

Updates to this Privacy Policy

This Privacy Policy was last updated in October 2025. CCS reserves the right to update and change this Privacy Policy from time to time, for example, in order to reflect any changes to the way in which CCS processes your Personal Information or changing legal requirements. In case of any such changes, CCS will post the changed Privacy Policy on CCS’ website or publish it otherwise. The changes will take effect as soon as they are posted on CCS’ website.

How to contact CCS

We welcome your views about CCS’ website and its Privacy Policy. If you have any questions about this Privacy Policy, please contact CCS Customer Support at assistants@cuatromarkets.com.

Third Party Links

By accessing other websites through links provided through the CCS website, you understand and agree that CCS has no control over such sites and resources and is not responsible for the availability of such external resources or the content, products, or other materials available through such external sites or resources.

No Recommendations or Investment Advice

CCS does not make recommendations or offer investment advice of any kind. You should not make any investment decision without first conducting your own research. You are solely and exclusively responsible for determining whether any investment or strategy or any other product or service is appropriate or suitable for you based on your investment objections and personal and financial situation. Any past performance indicated on the CCS website or provided through the Services is not indicative of future results. Anyone investing should be able and prepared to bear a loss of his or her entire investment. You agree to not hold CCS liable for any possible claim for damages arising from any decision you made based on information made available to you through the website or Services.

Effective as of October 8, 2025