Facts

 What Does Hapoalim Securities USA, Inc. (Hapoalim Securities) Do With your Personal Information?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

 The types of personal information we collect and share depend on the product or service you have with us. This information can include:

·         Social Security number and  other identifying information

·         Transaction history and  credit history

·         Account holdings and Account balances

When you are no longer our customer, we continue to share your information as described in this notice.

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Hapoalim Securities chooses to share; and whether you can limit this sharing.

 Reasons we can share your personal information

Does Hapoalim Securities share?

Can you limit this trading?

 For our everyday business purposes— such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus

Yes

No

 For our marketing purposes— to offer our products and services to you

Yes

No

 For joint marketing with other financial companies

No

We do not share

 For our affiliates’ everyday business purposes— information about your transactions and experiences

Yes

No

 For our affiliates’ everyday business purposes— information about your creditworthiness

No

We do not share

 For our affiliates to market to you

No

We do not share

 For nonaffiliates to market to you

No

We do not share

Who we are

Who is providing this notice?

HAPOALIM SECURITIES

What we do

How does Hapoalim Securities protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does Hapoalim Securities protect my personal information?

We collect your personal information, for example, when you:

·         Open an account or change an account

·         Add funds or provide income information

·         Provide account information

We may also collect personal information from others, such as credit bureaus,  affiliates, or other companies

Why can’t I limit all sharing?

Federal law gives you the right to limit only

·         sharing for affiliates’ everyday business purposes—information about your creditworthiness

·         affiliates from using your information to market to you

·         sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

·         Our affiliates include companies with the Bank Hapoalim name and other financial companies such as BankPozitif.

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

·         Non-affiliates we share with can include banking, regulatory and governmental agencies that supervise our affiliates.

Joint marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

·         Hapoalim Securities does not jointly market.