Privacy Policy and Certain Information Sharing

Imperial Capital, LLC (“Imperial” or “we”) appreciate the trust that you place in us and we recognize the importance of protecting the confidentiality of any nonpublic personal information that we may obtain about you. Obtaining this information is important to our ability to ensure accuracy in record keeping, carry out requested transactions and generate confirmations, statements and other reports. Keeping this information secure is a top priority for us.

As required by federal law, this Privacy Policy describes the types of nonpublic personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may disclose the information, and the steps we take to safeguard the information to protect your privacy. The term “Imperial” refers to Imperial Capital and its affiliates.

Sources of Information We Collect About You

The information we collect about you is primarily obtained from account applications or other forms and materials you submit directly to Imperial during the course of your relationship with us. We may also collect information about the transactions and interactions you engage in with or through us. In addition, we may verify information or obtain additional information about you from consumer reporting agencies or other sources. We do not share nonpublic personal information about you outside Imperial without your consent except for the specific purposes described below, in accordance with applicable laws.

In addition, in the provision of financial services to you and subject to strict compliance with applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g., recording of telephone calls and monitoring of emails and instant messages). In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used for compliance or security purposes.

Categories of Nonpublic Personal Information We Collect and Disclose

As a general matter, Imperial Capital collects the following categories of nonpublic personal information about you: (i) information received from you such as contact and financial ownership; and (ii) information about transactions with you or your affiliates.

If you deal with Imperial in your individual capacity, or as a settler/trustee/beneficiary of a trust, or as an owner or principal of a company or other entity organized to invest on your behalf or on behalf of your family, etc., the typical information we collect about you would include: your name, address and other contact information; your date of birth, occupation and marital status; extensive financial information, including net worth, sources of wealth, investment experience and objectives, risk tolerance and representations concerning your financial resources; certain identifying information as may be required by laws and regulations addressing money laundering, terrorism and related matters such as information from, as applicable, your passport, alien identification card, national identity card or driver’s license; and a government issued personal identifier, such as, depending on your country of residence, your Social Security number, National Insurance number, Tax File number, etc.

If you are an employee/officer/director/principal, etc., of one of our institutional customers, the typical information we collect about you would include: your name and other contact information; your role/position/title and area of responsibility; and certain identifying information as may be required by laws and regulations addressing money laundering, terrorism and related matters such as information from, as applicable, your passport, alien identification card, national identity card or driver’s license.

A corporation, partnership, trust, or other legal entity may need to provide other information such as its principal place of business, local office address, employer identification number, certified articles or certificate of incorporation or other charter document, government-issued business license, partnership agreement, or trust agreement.

You are not required to supply any of the personal information that we may request, but failure to do so, or if we are unable to verify your identity, may result in us being unable to open or maintain your account or to provide services to you. While we make every effort to ensure that all information we hold about you is accurate, complete and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.

We reserve the right to disclose all of the non-public personal information that we collect from you, as described below.

Reasons We May Disclose Your Nonpublic Personal Information and Persons To Whom We May Disclose This Information

As detailed below, Imperial Capital may disclose your nonpublic personal information to its affiliates and nonaffiliated third parties: (i) for everyday business purposes such as necessary to process transactions, maintain account(s), respond to court orders and legal investigations, or report to credit bureaus; or (ii) as permitted or required by law.

These third parties are: (i) financial service providers (e.g., clearing firms); (ii) non-financial companies (e.g., professional services firms such as accounting firms); and (iii) others persons as permitted or required by law (e.g., regulators).

In order to provide efficient and reliable services, and to improve product and service options available to you, more than one entity within Imperial may be given, or have access to your nonpublic personal information. When so sharing your nonpublic personal information, we adhere to applicable legal and industry standards regarding the protection of personal information. We do not share information between different Imperial entities to solicit you for marketing purposes. Imperial also does not disclose your nonpublic personal information to unaffiliated third parties, except as described in this Privacy Policy. Disclosures to third parties may include sharing information with non-affiliated companies (both financial service providers and non-financial companies) that perform support services for us or your account, such as facilitating your transactions with or through Imperial, including those that provide clearing, professional, legal or accounting advice, perform computer related or data maintenance or processing services, audit or research services, or for credit review or reporting purposes. Non-affiliated companies that assist Imperial in providing services to you are required to maintain the confidentiality of such information to the extent they receive it, and to use your nonpublic personal information only for the purpose of providing such services. We may also disclose your nonpublic personal information to fulfill your instructions, to protect our rights and interests, or pursuant to your express consent. Finally, under limited circumstances, your nonpublic personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations, for instance, when responding to subpoena or similar legal process, to protect against fraud, money laundering, and to otherwise cooperate with law enforcement or regulatory authorities or with organizations such as exchanges or clearing houses.

Except in those specific limited situations, without your consent, we will not share nonpublic personal information about you with other companies who may want to sell their products and services to you. For example, we do not sell customer lists and we will not sell your name to a catalogue company or telemarketer.

Limitations on Your Ability to “Opt Out” of Nonpublic Personal Information Disclosure

Federal law gives you the right to limit or “opt out” only with respect to Imperial Capital, LLC’s (i) sharing of information about your creditworthiness with its affiliates for their everyday purposes, (ii) affiliates from using your information to market to you, and (iii) sharing with non-affiliates in order to market to you.

As noted above, we do not disclose your nonpublic personal information for any of the reasons set forth in items in (i) – (iii).

How We Protect Information

We limit access to your nonpublic personal information to authorized Imperial employees and registered representatives acting on our behalf, and, as described above in Disclosures of Your Nonpublic Personal Information, our service providers are held to stringent standards of privacy. We also maintain physical, electronic and procedural safeguards designed to comply with applicable laws to guard against loss, misuse, damage or modification and unauthorized access or disclosure of your nonpublic personal information. We update and test our technology on a regular basis in order to improve the protection of customer nonpublic personal information.

Privacy and the Internet

Imperial Capital operates a website at Portions of this website require users to identify and authenticate themselves prior to accessing certain services. Generally, identification and authentication take place through the use of your user name and a password. Security is a cooperative effort between Imperial and the users of Imperial’s website. Please remember that your user name and password are personal to you and should not be made available to any other person. Also, you should discontinue your use and notify us if you have any reason to suspect that someone else may be using them.

On this website, we may use “cookies” or other technology to gather information about the website usage to help us improve the content, usability and functionality of the website, and to remember your personal settings. “Cookies” are small text files consisting of information stored on your Web browser. This information helps us authenticate you and make it easier for you to navigate the website by, among other things, “remembering” your identity so that you do not have to input your password multiple times as you move between pages or services. You can set your Web browser to inform you when cookies are set, or to prevent cookies from being set. However, if you decline to use cookies, you may experience reduced functionality, and declining to use authentication related cookies may prevent you from using certain services.

Our Former Customers

If your relationship with Imperial Capital ends, Imperial Capital will continue to treat your non-public personal information, to the extent we retain it, as described in this Privacy Policy.

Changes to Our Privacy Policy

We reserve the right to change this Privacy Policy at any time to reflect changes in our practices concerning the collection and use of nonpublic personal information. If there are material changes to this Privacy Policy, the revised policy will be effective immediately upon posting to our external website. This version of our Privacy Policy is effective as of December 2014.

Additional Information

If you require further information regarding our privacy policies and practices, please feel free to contact us at or at (310) 246-3700.