Our Commitment to Privacy

View the National Financial Services LLC Privacy Notice

National Financial Services LLC Privacy Policy

As you may know, your broker-dealer and National Financial Services LLC ("NFS") have an agreement through which NFS provides clearing and other related services for your account. In connection with these services, NFS is required to communicate its practices regarding the privacy of customer information. These practices also apply to you if you have a retirement account through your broker dealer for which Fidelity Management Trust Company (FMTC), an affiliate of NFS, is the custodian. Additionally, if your broker-dealer offers managed account services through the Fidelity Managed Account XchangeSM, a managed account platform sponsored by Fidelity Institutional Wealth Adviser LLC ("FIWA"), a registered investment advisor affiliate of NFS, FIWA will follow these privacy practices as well. You do not have to contact your broker-dealer to benefit from these protections; they apply automatically to all customers. We review our privacy policy annually. Our printed and online notices are then updated to reflect any changes. In this policy, personal information means information about an individual that is collected or maintained for business purposes and by which the individual can be identified.

How and Why We Obtain Information

To facilitate the servicing of your account, NFS may receive non-public personal information about you from you, your broker-dealer and from any of the following sources:

• Your applications or forms (for example, name, address, Social Security number, birth date, assets, and income)
• Transactional activity in your account (for example, trading history and balances)
• Information from consumer reporting agencies (for example, to assess your creditworthiness for margin products)
• Information from other third-party data services (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 broker-dealer (for example, from other institutions if you transfer positions into NFS)

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

NFS considers the protection of personal information to be a foundation of customer trust and a sound business practice. We employ physical, electronic, and procedural controls, and we regularly adapt these controls to respond to changing requirements and advances in technology. Within NFS, we restrict access to your information to those who require it to develop, support, offer, and deliver products and services to you.

How We Share Information About You

We may share the personal information that we collect about customers, prospects, or former customers with their broker-dealers or with:

• NFS corporate affiliates, including internal service providers (for example, our data processing company and printing operation)

• Unaffiliated service providers (for example, printing and mailing companies, securities clearinghouses, and other entities who may provide services at NFS' direction)

• Government agencies, other regulatory bodies, and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions)

• Other organizations, with your consent or as directed you or your broker-dealer (for example, if you request personalized performance reporting) or as permitted or required by law (for example, for fraud prevention or to respond to a subpoena)

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

Your Digital Privacy

Privacy, security and service in Fidelity's online operations are just as critical as in the rest of our business. We use firewall barriers, encryption techniques and authentication procedures, among other controls, to maintain the security of your online session and to protect Fidelity accounts and systems from unauthorized access.

When you interact with us by using our websites, online services or mobile applications that are owned and controlled by NFS ("our digital offerings"), NFS manages personal information in accordance with all of the practices and safeguards described previously.

When you use our digital offerings, we may 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 online session, facilitating site navigation, improving NFS website design and functionality, and personalizing your experience. Additionally, the following policies and practices apply when you are online.

Cookies and similar technologies

We use cookies and similar technologies to support the operation of 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. NFS cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.

You can refuse or delete cookies. Most browsers and mobile devices offer their own settings to manage cookies. If you refuse a cookie, or if you delete cookies from your device, you may experience some inconvenience in your use of our digital offerings or, in some cases, may not be able to use a particular digital offering.. 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.

NFS also uses tools, such as Google Analytics, on certain websites to help us analyze how you and other visitors use our website and to improve its functionality. NFS does not provide any personal information about you to Google Analytics and any information collected by Google is done anonymously without identifying an individual user. We do not associate information collected by Google Analytics with information you may have provided to us. For more information on Google Analytics, including how to opt-out, click here.

Connecting with NFS on social media platforms

NFS provides experiences on social media platforms that enable online sharing and collaboration among users who have registered to use them. We may collect information you provide by interacting with us via social media, such as photographs, opinions, or social media account ID. Any content you post, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms, is also subject to the Terms of Use and Privacy Policies of those platforms. Please refer to them to better understand your rights and obligations with regard to such content.

NFS mobile applications

NFS mobile applications ("apps") allow you to access your accounts, trade securities, move money, and access third-party news and research using wireless or mobile devices. Our privacy practices apply to any personal information or other information that we may collect through the apps.

Protecting children's privacy online

NFS websites are not directed to individuals under the age of thirteen (13). NFS does not intentionally collect information on NFS websites from those we know are under 13, and we request that these individuals do not provide personal information through the sites.

Access to Your Information

You may access and, if necessary, correct your account information through a variety of means offered by your broker-dealer and NFS (for example, via online services). Please contact your broker-dealer for more information about how you may correct your account information.

This privacy policy is provided to customers of correspondent broker-dealers on behalf of National Financial Services LLC.

If you are a shareholder in one or more of Fidelity funds, please review the following policy. This privacy policy is reviewed annually. The printed and online notice are then updated to reflect any changes.

The following statement only applies to you if you buy Fidelity Funds through your broker-dealer.

Fidelity Funds Privacy Policy

Protecting your personal information is an important priority for the Fidelity Funds. The Funds' privacy policy is designed to support this objective. The Funds collect non-public personal information concerning you in the following ways:

• Information provided by you or your representative on applications or other forms furnished to the Funds or through other interactions that you or your representative have with the Funds
• Information arising from your investments in or accounts with the Funds
• Information the Funds receive from a consumer reporting agency

The Funds employ physical, electronic, and procedural controls to safeguard your information. For example, the Funds authorize access to your personal and account information only for personnel who need that information in order to provide products or services to you.

The Funds do not disclose any non-public personal information about you, except as permitted by law. For example, the Funds have entered into a number of arrangements with Fidelity Investments to provide for investment management, distribution, and servicing of the Funds.

If you decide to close your account, the Funds will continue to adhere to the privacy policies and practices as described in this notice.

Please read the Fidelity Funds Privacy Policy in conjunction with the Privacy Policy for the Fidelity Investments companies of which you are also a customer.

Additional Information

If you are a former customer, your information is treated in the same manner as the information of current customers.

Fidelity offers several options for accessing and, if necessary, correcting your account information. You can review your information using your statements, or through our automated telephone or Internet services. You may also write or call us with your request for information. If we serve you through an investment professional, please contact them directly. Specific Internet addresses, mailing addresses, and telephone numbers are listed on your statements and other correspondence.

Privacy Policy Supplement - CCPA

This Additional Information for California Residents ("Supplement") supplements the National Financial Services LLC Privacy Policy. This Supplement is provided for purposes related to the California Consumer Privacy Act of 2018, as amended (the "CCPA"), and applies to the personal information and your relationship(s) with NFS and other Fidelity companies that are subject to the CCPA. As used in this Supplement, "personal information" means information that is considered to be personal information as set forth in the CCPA and is not otherwise excluded from the scope of the CCPA. The information herein pertains only to individuals at the broker-dealer firms and other institutional firms whose personal information may be collected by NFS.

Depending on the Fidelity company with which you have a relationship or otherwise interact, and on the nature of your relationship and interactions with that Fidelity company, and on the products and services provided to you through that relationship, some or all of the personal information that the Fidelity company collects or maintains is covered by one or more of the exemptions described below (see "CCPA Exemptions" below). As a result, in some cases, the applicable Fidelity company may have no obligation under the CCPA to accept any CCPA requests, and in other cases, it may have no obligation to honor a particular CCPA request, because of the nature of the personal information that the Fidelity company collects or maintains. Here are some examples:

• If your relationship and interactions with NFS consists solely of personal financial services (e.g. maintaining one or more personal brokerage accounts), the personal information collected and processed about you is subject to the federal Gramm-Leach-Bliley Act ("GLBA") and therefore your CCPA requests will not be honored by NFS.
• If you have an institutional relationship (e.g., you are a representative of a registered investment advisor, broker-dealer, bank or trust) with NFS, information collected about you in the context of that business relationship is not covered by the CCPA and therefore NFS has no obligation to honor any CCPA requests submitted by you.
• If your interaction with NFS is solely as a business customer of NFS, personal information collected is not covered by the CCPA and therefore NFS will not honor any CCPA requests submitted by you.

Information regarding the CCPA

The CCPA gives certain rights to California residents and imposes certain obligations on those businesses that are subject to the CCPA. As required by the CCPA, set forth below is a description of certain rights that California residents generally have under the CCPA. As used below, a "consumer" means a resident of the State of California and a "covered business" means a business that is subject to the CCPA.

• A consumer has the right to request that a covered business that collects a consumer's personal information disclose to that consumer the categories and specific pieces of information the business has collected. A consumer also has the right to request that a covered business that collects a consumer's personal information disclose to that consumer the following:
  
  1. the categories of personal information it has collected about that consumer,
  2. the categories of sources from which the personal information is collected,
  3. the business or commercial purpose for collecting or selling (if applicable) personal information,
  4. the categories of third parties with whom the covered business shares personal information, and
  5. the specific pieces of personal information that the covered business has collected about that consumer.
  These disclosures are not required to include any information about activity that occurred earlier than 12 months before the date the covered business received the consumer's request.
• A consumer has the right to request that a covered business delete any personal information about the consumer that the business has collected from the consumer. However, the covered business is not required to comply with such a request if the covered business needs to maintain the consumer's personal information for certain purposes set forth in the CCPA.
• A consumer has the right to request that a covered business delete any personal information about the consumer that the business has collected from the consumer. However, the covered business is not required to comply with such a request if the covered business needs to maintain the consumer's personal information for certain purposes set forth in the CCPA.
  
  1. categories of personal information that the covered business collected about the consumer,
  2. the categories of personal information that the covered business sold about the consumer and the category of third parties to whom the personal information was sold, by category of personal information for each category of third party to whom the personal information was sold, and
  3. the categories of personal information that the covered business disclosed about the consumer for a business purpose.
• A consumer has the right to direct that a covered business that sells personal information about the consumer to third parties not sell the consumer's personal information.
• A covered business cannot discriminate against a consumer because the consumer exercised any of the consumer's rights under the CCPA.

As described in this section the requests that a consumer can make to a covered business are referred to as "CCPA requests".

CCPA Exemptions: Please note that certain types of personal information collected or maintained by a covered business are exempt from the CCPA. For example, a covered business has limited obligations, or in some cases no obligations, under the CCPA with regard to the following types of personal information:

• personal information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act, (Public Law 106-102), and implementing regulations, or pursuant to the California Financial Information Privacy Act (Division 1.4 [commencing with Section 4050] of the California Financial Code)
• medical information governed by the Confidentiality of Medical Information Act (Part 2.6 [commencing with Section 56] of Division 1 of the California Civil Code) or protected health information that is collected by a covered entity or business associate governed by the privacy, security, and breach notification rules issued by the United States Department of Health and Human Services, Parts 160 and 164 of Title 45 of the Code of Federal Regulations, established pursuant to the Health Insurance Portability and Accountability Act of 1996 (Public Law 104-191) and the Health Information Technology for Economic and Clinical Health Act (Public Law 111-5)
• personal information collected from a job applicant, employee, owner, director, staff member, officer or contractor of a covered business when the information is used by the covered business within the person's role as a job applicant, employee, owner, director, staff member, officer or contractor of the covered business
• personal information about an employee, owner, director, officer or contractor of another business that is collected by the covered business in connection with due diligence activities regarding the other business, or in connection with the covered business providing a product or service to or receiving a product or service from the other business

In addition, some businesses are not subject to the CCPA, such as:

• a business that does not do business in the State of California
• a business that is not organized or operated for the profit or financial benefit of its shareholders or other owners
• a business that does not determine the purposes and means of the processing of consumers' personal information
• a business that has annual gross revenue of $25,000,000 or less

Furthermore, under the CCPA there are a number of situations where a covered business may refuse to honor a CCPA request to delete a consumer's personal information and is allowed to continue to maintain the consumer's personal information. Some examples include situations where retention of the personal information is necessary to:

• complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of the covered business's ongoing business relationship with the consumer, or otherwise perform a contract between the covered business and the consumer
• detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity
• exercise free speech or another right provided for by law
• enable internal uses that are reasonably aligned with the expectations of the consumer based on the consumer's relationship with the covered business
• comply with a legal obligation
• otherwise use the consumer's personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information

Please note that the description of the CCPA set forth above is a summary of only certain aspects of the CCPA and is not, and should not be considered to be, a complete description of the CCPA. In addition to what is described above, the CCPA includes other exemptions that apply to particular types of personal information and particular businesses, as well as additional situations where a covered business is not required to honor a consumer's request to delete the consumer's personal information.

Also, because we do not sell personal information, Fidelity companies do not have any obligation under the CCPA to accept CCPA requests requesting that the Fidelity company not sell a consumer's personal information.

Categories of personal information NFS may collect about you

• Personal identifiers, such as your name, address, email address and other unique identifiers
• Information covered by California's records destruction law (California Civil Code §1798.80), such as your signature and telephone number
• Characteristics of protected classifications under California or US federal law, for example, gender
• Commercial information
• Internet/Electronic network interactions
• Audio/Electronic/Visual data
• Professional or employment related information
• Education Information
• Inferences drawn from any of the information listed above to create a profile about you, such as a profile that reflects your preferences and characteristics

Categories of sources from which personal information is collected

Please see the section above titled "How and why we obtain information" for a description of some of the categories of sources from which we collect personal information. In addition to the sources described in that section, depending on the nature of your relationship and your interactions with us, and on the products and services that we provide to you, we may obtain personal information from the following sources:

• you or your representative when interacting with us or any of our digital offering and apps or when otherwise communicating with us
• publicly available information
• third parties that provide products or services to you through your relationship with us
• third parties that perform services for us or on our behalf

Why NFS collects personal information

Business and commercial purposes for which we collect personal information are to provide you information about products and services that may interest you, marketing and communication purposes, to protect against malicious, fraudulent, or illegal activity; to adhere to applicable laws and regulations, and other internal business purposes.

How NFS shares information about you with third parties

NFS may share personal information about you with unaffiliated third parties that provide products or services to you through your relationship with NFS or your broker-dealer. NFS does not sell personal information about you and has not done so at any time during the 12-month period preceding the effective date of this Privacy Policy. As required by the CCPA, NFS hereby states that NFS does not sell personal information of minors under 16 years of age.

If you wish to submit a CCPA request to NFS, you may initiate your request through one of the options below. Before submitting your request, please ensure you have reviewed the CCPA Exemptions above as well as the cases detailed above where NFS may have no obligation under the CCPA to accept any requests.

• Customers of a broker-dealer for which NFS provides services should contact their broker-dealer for instructions on submitting a request.
• NFS Correspondent clients can contact Fidelity Institutional at 877-262-5950
• Capital Markets clients can contact Fidelity Capital Markets at 800-280-6355
• Visit Additional Information for California Residents
  

NFS received no CCPA requests for disclosure of personal information (request to know) and no requests for deletion of personal information (request to delete) between January 1, 2020 and December 31, 2020.F

For questions or concerns about NFS' Privacy Policy and privacy practices, institutional clients should contact their NFS representative, and all others can call 800-877-2410.