Privacy Policy

Gateway Capital’s Commitment to Client Privacy
At Gateway Capital the commitment to maintaining trust and confidence is always on display, particularly when it comes to privacy. For Gateway clients and new visitors, we want you to understand how we protect your privacy, the information we collect and the steps we take to safeguard that information.

Gateway does not retrieve account or personal information its servers when a client or visitor browses the public (pre-login) areas of our websites. Gateway does aggregate information on our site to identify general web site traffic patterns and site usage, such as how many people visit the site, pages they visit, how long they stay on the site, and the domain name of the site visitors connect from (e.g., yahoo.com). This data is collected on a aggregate basis and is not attached to an individual visitor.

Gateway’s Security Measures
As a visitor to the Gateway web site who submits information in one of our online account forms, your information is protected through the use of Secure Sockets Layer (SSL0 encryption technology. This SSL technology, compliant with industry standards, is designed to protect this information from unauthorized use and is used with other safeguards such as firewalls, authentication systems (i.e.: passwords and personal identification numbers) to prevent unauthorized access to personal data.

Hyperlinks and Cookies
Gateway’s websites may contain "links" to other sites, and other sites may "link" to the Gateway site. Gateway is not responsible for content nor the privacy policies of third party web sites, and some of these sites may have privacy practices different from that of Gateway. This Website Privacy Statement only applies to the Gateway web site and does not apply to websites where links are pointed to Gateway or where Gateway points to other sites. If you elect to link to a co-branded website or to a linked website, you may be asked to provide registration or other information. Please note that the information you are providing is going to a third party and you should familiarize yourself with the privacy policy provided by that third party.

Cookies are text files that a website transfers to your hard drive or browser for tracking your website usage. Gateway does not use cookies to gather personal information such as a person's name or email address. We do, however, use cookies to identify repeat visitors to our websites, to determine the path visitors take to our websites, and to identify visitors who came to Gateway as a result of a banner ad on a third party website. Please note that third party web sites may have different policies regarding cookies, and we are not responsible for the actions or policies of such third parties.

In the event visitors provide Gateway with personal information about themselves – such as name, address, phone number, email address – for the purpose of receiving information about our products and services, or if you are an Gateway client and we obtain from you or from other sources non-public personal information about you in the course of providing you with our products and services, the following are the steps we take to safeguard such non-public personal information.

Security Procedures
Gateway restricts access to Personal Information about you to:

1. Our employees and affiliates who need to know that information in order to provide the products and services you receive from us.
   
2. Those unaffiliated third parties whose access to such information is permitted or required by law and who need to know that information in order to assist us in providing you with the products and services you receive from us.
   
3. Those unaffiliated third parties whose access to such information is necessary in order for Gateway to engage in joint marketing efforts with such unaffiliated third parties.
   
4. Those unaffiliated brokers who have introduced you to us, if applicable ("Introducing Brokers").
   

To protect the security of Personal Information, we maintain physical, electronic, and procedural safeguards that comply with federal standards for guarding the information we collect about our web site visitors.

Information We Collect
In providing you with financial products and services, or information about such services, (Who is Gateway, Should be Gateway) Gateway may collect the following types of Personal Information:

1. Information we receive from your Introducing Broker (if applicable) or from you on account applications, whether written or electronic, or on other forms (including on-line forms). This information would include your name, address, social security number, income, investment experience, and so forth.
2. Information about your transactions with us, our affiliates, or others. This information could include your trading through us, our affiliates and others, your history of meeting margin calls, and your use of the various products and services that we and our affiliates provide.
   
3. Information about your creditworthiness, credit history, and other information about you that we receive from consumer reporting agencies, our affiliates, your Introducing Broker (if applicable), or providers of other demographic information, such as your purchasing or investment preferences.
   
4. Information about you obtained in connection with our efforts to protect against fraud or unauthorized use of your account(s) with us.

Information We Disclose

Gateway may disclose to unaffiliated third parties with which Gateway is engaged in a joint marketing arrangement Client Information such as:

1. Information we receive from your Introducing Broker or from you on account applications, whether written or electronic, or on other forms. This information would include your name, address, social security number, income, investment experience, and so forth.
   
2. Information about your transactions with us, our affiliates, or others. This information could include your trading through us, our affiliates and others, your history of meeting margin calls, and your use of the various products and services that we and our affiliates provide.
   

Categories of Parties to Which We May Disclose
Gateway may disclose the types of Personal Information to the following types of third parties:

1. Financial service providers, such as introducing brokers, broker-dealers, futures commission merchants, investment companies, investment advisers, commodity trading advisors, and commodity pool operators.
   
2. Gateway suppliers that perform marketing services on our behalf or to other financial institutions with which we have joint marketing agreements to sell Gateway products or services.
   
3. Publishers and other direct marketers of products related to the financial services industry, such as newsletter or book publishers and software or trading system developers.
   
4. We may also disclose Personal Information to other non-affiliated third parties as permitted or required by law, such as in response to a subpoena or legal process or in order to complete a transaction which you initiated and authorized.
   

Privacy Updates and Opt Out
Gateway may, from time to time, make changes to this Website Privacy Statement. You will not be able to access your account information or place an order until you agree to the terms of the revised Statement.

If you prefer you may choose that we not disclose your Personal Information to third parties. That is, you may direct us not to make those disclosures (other than disclosures permitted or required by law). You, however, may not opt out of Personal Information disclosed about you to your Introducing Broker (if applicable), or any service provider necessary to effect or process any -+transaction in your account(s) with us (if applicable). If you wish to opt out of disclosure to non-affiliated third parties, you may email us at optout@gatewaycapital.com stating that you wish to opt out of all information sharing of your Personal Information.

Joint Account/Partnership Procedures
If you have a Gateway account, and if your account(s) with us is for joint tenants with rights of survivorship, tenants in common, or a general partnership, any one party to the account may elect to opt out for the account. That opt out election will bind all parties to the account.
ONLINE SERVICES

If you register for our online products or services, we retain your user ID and password and other information about your use of our websites in order that we may recognize you as a registered user. We may obtain your email address from you or from another source. We may send you email offers for our as well as our affiliates' products and services. We may also send you emails for third party products and services we think may be of interest to you. All email offers we send to you include an opportunity to opt out from future email offers.

If you opt out from receiving email offers, we may still send (via email or otherwise) important information about your account(s) with us (if applicable) and our products and services.