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:

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:

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:

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:

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.

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:

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

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:

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

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:

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.

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.