MBF - privacy

Privacy Policy

MBF CLEARING CORP.

PRIVACY POLICY- JULY, 2008

MBF has always worked hard to maintain the highest standards of confidentiality and to respect the privacy of our customers. In that regard, we are providing this Privacy Notice to all of our individual customers.

This notice is to satisfy disclosure requirements under the Gramm-Leach-Bliley Act of 1999 and the CFTC Regulation 160.

GENERAL INFORMATION ABOUT BROWSING MBF'S WEBSITES

No account or personal information is retrieved from MBF's servers when a client or visitor browses the public areas of our websites. The only data that is gathered may include (1) how many people visit the website; (2) the pages they visit; (3) the domain name of the site visitors connect from (e.g. google.com).

COLLECTION OF INFORMATION

MBF collects nonpublic personal information about its customers through the following sources:

1. Information from the customer.

2. Information about the customer from the customer's transactions with us or our affiliates.

3. Information about the customer from the customer's reporting agency[ies].

Sources of such information include, without limitation, 1) applications forms, 2)

questionnaires; and (3) other information that you provide to us; whether in writing, in person, by telephone, electronically or by any other means. This information may include your name, address, social security number, financial and investment qualifications, income, employment information, income and credit references. Sources of such information also include information received regarding trading and investment activity done by you or for your benefit which is reported to our company.

By using our web site, applying for or opening an account with us, you consent to the collection and use of information as set forth in this Privacy Policy

DISCLOSURES TO SERVICE PROVIDERS

MBF uses carefully selected firms to perform services such as preparing, printing and delivering statements and other documents, on-line trading execution systems, protection against fraud or maintaining or developing software for us which enables us to perform the tasks required as a clearing firm. We provide only the information they need to offer our services to you. All these companies must conform to our confidentiality requirements and our Privacy Policy and are not permitted to use the information or contact our customers for any purpose other than to carry out the tasks specified by MBF.

MBF may also be legally required to exchange certain information about its customers with specific credit reporting agencies, in response to a court order, to prevent fraud or to comply with a requirement of a government agency.

We do not share or sell information about MBF customers or former customers to unaffiliated third parties.

DISCLOSURES PERMITTED BY LAW

We may disclose all the personal information we collect as permitted or required by law. For example, we may disclose information to law enforcement agencies or regulatory authorities (such as the CFTC, NFA or the DSRO), to respond to a subpoena or court order or judicial process, to consumer reporting agencies, to comply with a requirement of a government agency (such as pursuant to the US Patriot Act) or in connection with a proposed or actual sale, merger, or transfer of all or a portion of a business or an operating unit;

We may also disclose information upon consent of an investor to release such information, including authorization to disclose such information to persons acting in a fiduciary or representative capacity on behalf of the investor.

NO DISCLOSURES FOR OTHER PURPOSES

We will not share any personal information we collect with outside companies, except as explained above. That is, we will not sell personal information to outside companies that may wish to market their products and services to you. While we may offer products or services to you on behalf of such outside companies, we will not give your personal information to them

COOKIES

When you visit our website, our computer may use devices known as “cookies”. Cookies are files that reside on your hard drive that enable you to move quicker through a particular website or it helps track your website usage. MBF does not use cookies to gather personal information. MBF does use cookies to identify repeat visitors to our websites, and to determine the path you took to access our website. MBF receives this information on an aggregate basis and anonymous basis. If you set your browser to reject cookies, you may not be able to access our website.

Third parties might also create cookies when you access their sites through links posted on our sites. MBF does not have access to any cookies that may exist on these other websites. You would need to contact the third party vendors directly to obtain their policies regarding cookies. We are not responsible for the actions or policies of such third parties.

ANNUAL NOTIFICATIONS

If you are a current customer, we will provide an annual Privacy Policy notice to you. If you no longer have a customer relationship with us, we will continue to follow our Privacy Policy and practices, but you will not receive future notices from us.

SECURITY PROCEDURES

We maintain procedures and technology designed to prevent unauthorized access to personal information. We maintain physical, electronic, and procedural protections in accordance with applicable standards to protect personal information. We restrict access to personal information to employees and service providers for legitimate business purposes to assist in providing products or services to you. Employees who violate our Privacy Policy are subject to disciplinary action. Third-parties with which the Company shares member information must agree to follow appropriate standards of security and confidentiality.

You can also take steps to protect the security of your computer:

• K eep your computer and browser software current with security updates.

• I nstall and update anti-virus and anti-spyware software and use personal firewalls to protect your computer.

• Be alert to the threats posed by malware--short for malicious software, this form of software is designed specifically to damage or disrupt a system, or to secretly record information such as keystrokes. Malware types include key logging tools, trojan horses, hijacking programs, and dialer programs that may reside on your personal computer. While these threats constantly evolve, you can help protect your personal information and computer by using a personal firewall, maintaining up-to-date anti-spyware and anti-virus programs, and by immediately reporting any suspicious activity involving your personal information.

• Do not enable any application features that would automatically log you in to your MBF Clearing Corp. account or pre-fill the Login ID or Password fields.

• Change your password periodically and avoid using passwords for MBF Clearing Corp. that you commonly use for other purposes.

• For more information on how to protect your personal computer, including links to vendors providing anti-virus and anti-spyware software, please visit the Federal Trade Commission's computer security site at http://onguardonline.gov . Microsoft Corporation provides additional information specific to the Windows operating system at http://www.microsoft.com/security . Users of Apple computers can find security information at http://www.apple.com/support/security .

LINKS TO OTHER WEB SITES

We are not responsible for the information collection practices of other Web sites when you link to them from our Web site. For example, we cannot guarantee how those sites use cookies or whether they place on your computer cookies that may identify you personally. If you choose to link to one of these websites, you may be asked to supply registration or other information. It is important that you realize this information is going to a third party, and you should become familiar with the privacy policy provided by that third party. You should carefully review the privacy policies of each Web site you visit to understand how they collect, use, and disclose information.

ENCRYPTION

We use encryption and authentication tools to protect your personal information. E-mails you send us are not necessarily secure when they are transmitted to us. If your communication is very sensitive, you may want to call us or send it by regular mail.

We may also collect nonpublic personal information when you use our corporate web sites. Information is obtained through online collecting devices known as “cookies”

CHANGE IN PRIVACY POLICY

We reserve the right to modify or supplement this Privacy Policy at any time. If we make material changes, we will provide current customers with a revised notice that describes our new practices.

The practices and policies contained in this Privacy Policy replace all previous notices or statements with respect to the same subject.

PRIVACY INQUIRIES

If you have any question about our Privacy Policy or about the security and confidentiality of your non-public personal information, please call our office at 1-212-845-5100 and someone will be pleased to assist you.