QuinFi privacy policy

This privacy policy describes QuinFi’s collection, use and sharing of personal information. As used in this privacy policy, "QuinFi" refers to QuinFi Brokerage Services LLC and the other Fidelity companies that offer products and services available through this website and mobile applications where this policy appears.

QuinFi ("we") may offer products, services and digital offerings that may have a different or additional privacy policies made available to You if you choose to use those products, services or digital offerings. Some products and services available on our Digital Properties may have supplemental privacy policies that pertain to those products and services.

As used in this privacy policy ("policy"), personal information means information about an individual that is collected or maintained for business purposes and by which the individual can be identified. Please note that information by which an individual cannot be identified (for example, anonymous, de-identified, or aggregate information) is not considered personal information and therefore is not subject to this policy.

Please note that certain details of this policy may depend on whether you deal with us through an investment professional, directly as an individual investor, or whether QuinFi provides services to your employer or plan sponsor.

This policy is reviewed annually and updated to reflect any changes.

How and why we obtain and use personal information

QuinFi recognizes the importance of maintaining personal information about you and when we use it, we do so with respect for your privacy. We obtain and use personal information about you to service, maintain, and protect your account; process transactions in your account; respond to inquiries from you or your representative; develop, offer, and deliver products and services; operate and manage our business; and fulfill legal and regulatory requirements. QuinFi collects public and non-public personal information from customers and visitors from various sources. Some examples include:

• You or your representative on applications or forms (for example, when you interact with our customer service staff, and when you visit our websites or use our applications)
• You or your representative regarding your preferences (for example, your choice of electronic statement delivery, or the screen layout you specify if you use our websites)
• You or your employer or plan sponsor if QuinFi provides them with recordkeeping and/or employee benefits advisory services (for example, payroll, human resources, or benefits information)
• Transactional activity in your account (for example, trading history and balances)
• Other interactions with QuinFi (for example, discussions with our customer service staff, including telephone or chat, information you enter into our websites, or when you enroll in our authentication services)
• Information from consumer reporting agencies (for example, to assess your creditworthiness for margin products)
• Information from other third-party sources (for example, to verify your identity and to better understand your product and service needs)
• Other sources with your consent or with the consent of your representative (for example, from other institutions if you transfer positions into QuinFi)

Please note that information by which you cannot be identified (for example, anonymous or aggregated information) is not considered personal information and therefore is not subject to this privacy policy.

How we protect information about you

We implement and maintain physical, administrative, technical and organizational measures designed to protect personal information and we regularly adapt these controls to respond to changing requirements and advances in technology.

At QuinFi, we restrict access to personal information to those who require it to develop, support, offer and deliver products and services to you and to operate our business.

How we share information about you with third parties

QuinFi does not share or sell personal information about our customers with unaffiliated third parties for use in marketing their products and services. We may share personal information with the following entities:

• Unaffiliated service providers (for example, printing and mailing companies, securities clearinghouses, marketing service providers, and other entities who may provide services at QuinFi's direction)
• Government agencies, other regulatory bodies and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions)
• Other third-parties, with your consent or as directed by your representative (for example, if you request to transfer assets from another financial institution, or if you use an external aggregation website or service that you have provided permission to access your QuinFi financial account on your behalf)
• Other third parties whose products, services and investment offerings are made available through QuinFi, and which you decide to utilize
• Other organizations as permitted or required by law (for example for fraud prevention or to respond to a subpoena)
• In connection with corporate business transactions, such as a merger or sale of a business.

Our service providers are obligated to keep the personal information we share with them confidential and use it only to provide services specified by QuinFi.

In addition, if you choose to use or indicate your interest in using a product, service or investment offering that is offered by a third party and made available through QuinFi, we may share personal information with that third party in connection with your use or interest of that product, service or investment offering.

Based on the nature of your relationship with QuinFi, we may exchange information with other third parties as described below:

• If QuinFi provides workplace services to your employer or plan sponsor, such as payroll, human resources or employee benefits advisory and/or recordkeeping services, QuinFi may exchange any information received in connection with such services with your employer or plan sponsor or others they may authorize.
• If you conduct business with QuinFi through your investment professional, we may exchange information we collect with your investment professional or with others they may authorize.
• If you transact business through QuinFi's life insurance companies, we may share personal information with and obtain information about you from an insurance support organization. The insurance support organization may further share your information with other insurers, as permitted by law. We may also share medical information about you to learn if you qualify for coverage, to process claims, to prevent fraud, or otherwise at your direction, as permitted by law.

How we provide information about you to our affiliates

We may provide personal information about you to various QuinFi corporate affiliates including internal service providers which perform, for example, printing, mailing, and data processing services or for other business purposes.

If you interact with QuinFi directly as an individual investor (including joint account holders), we may provide certain information about you to QuinFi affiliates, such as our brokerage and insurance companies, for their use in marketing products and services as allowed by law.

Where QuinFi provides services to you under an arrangement with your employer or plan sponsor, to the extent permitted by you or under our agreement with your employer or plan sponsor and as allowed by law, we may provide information about you to QuinFi's affiliates, such as our brokerage and insurance companies, for their use in marketing products and services.

Information collected from investment professionals' customers is not provided to QuinFi affiliates for marketing purposes, except with your or your representatives' consent and as allowed by law.

Your digital privacy

When you interact with us by using our websites, online services or applications (including mobile apps) that are owned and controlled by QuinFi Investments ("our digital offerings"), or via electronic communications, QuinFi manages personal information in accordance with all of the practices and safeguards described in this policy.

When you use or interact with us via our digital offerings, or interact with us via electronic communications, we (or our service providers on our behalf) may automatically collect technical and navigational and location information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on our digital offerings. We use this information for a variety of purposes, such as maintaining the security of your session, facilitating site navigation, improving the design and functionality of our digital offerings and electronic communications, and personalizing your experience. Additionally, the following policies and practices apply when you are online.

Cookies and similar technologies

QuinFi and our third-party service providers may use cookies and similar technologies ("cookies") to support the operation of and maintain our digital offerings. Cookies are small amounts of data that a website or online service exchanges with a web browser or application on a visitor's device (for example, computer, tablet, or mobile phone). Cookies help us to collect information about users of our digital offerings, including date and time of visits, pages viewed, amount of time spent using our digital offerings, or general information about the device used to access our digital offerings. QuinFi cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.

Both QuinFi and third-party service providers we hire, such as Google and Meta, may use cookies and other technologies, such as web beacons, tags, or mobile device ID, in online advertising as described below. Most browsers and mobile devices offer their own settings to manage cookies. If you use those settings to refuse or delete cookies it may negatively impact your experience using our digital offerings, as some features and services on our digital offerings may not work properly. For example, you may not be able to sign in and access your account, or we may not be able to recognize you, your device, or your online preferences. Depending on your device and operating system, you may not be able to delete or block all cookies.

We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for our digital offerings, to improve the effectiveness of our online advertising and to understand more about the demographics of our users. You can learn more about Google's practices with Google Analytics by visiting Google's privacy policy. You can also view Google's currently available opt-out options.