Our Privacy Policy

Please read this carefully. It provides information about the privacy policy of MB Trading and MB Trading Futures, Inc., (collectively referred to as "we," "us," and "our" throughout this policy), which are affiliates under common control. This privacy policy concerns nonpublic personal information about current and former accountholders.

PRIVACY POLICY CONFIDENTIAL TREATMENT OF CUSTOMER INFORMATION

Did you know a federal law exists that regulates the collection, use and safeguarding of your nonpublic personal financial information by: (1) banks; (2) securities, futures and forex industry members; (3) insurance companies; and (4) other financial institutions. "Nonpublic personal financial information" is defined as specific information that is not available to the general public.

Before a company can share your nonpublic personal information that you have entrusted with them, they are required to notify you in advance of the sharing arrangement, and to give you ample time to opt-out.

It is our desire to keep you informed of changes in federal, state or self-regulatory organization rules and regulations that may have an impact on how we conduct our business.

OUR COMMITMENT TO YOUR PRIVACY

We understand the importance of maintaining the privacy of your personal and financial information. By entrusting us with your information, we would like to assure you of our commitment to keeping it private. We have taken measurable steps to protect the confidentiality, security and integrity of your information.

This notice will help you understand our overall privacy policy and the type of information that we collect, use and protect, which will also be provided to you on an annual basis.

PRIVATE POLICY SUMMARY

We collect personal and financial information to open your account, to process your transactions, to administer your account, to verify your identity, employment, creditworthiness, and to carry out your request for other products and services. The following categories are examples of personal nonpublic information that will be requested from you: (1) name, (2) date of birth, (3) trading history, (4) total assets, (5) social security number, (6) cash balance, (7) margin information, and (8) positions. We have implemented procedures to protect your nonpublic personal and financial information.

We do not disclose your nonpublic information to nonaffiliated third parties unless to facilitate your written requests or instructions, or it is permitted or otherwise required by law. Examples of "permitted by law" include our clearing firms: Penson Financial Services, Inc. (which clears and settles your securities transactions) and Penson GHCO (which clears and settles your futures transactions); and credit bureaus (e.g. Experian, Equifax, and Trans Union). "Required by law" examples include court orders and regulatory investigations.

We do not sell your personal information to third-party marketers or any other entity for any purpose.

Our commitment to privacy protection extends to both current and former customers, except as permitted or required by law.

RESOURCES

Our employees or representatives may collect nonpublic personal information about you from various sources including:

• Your account application or other supplemental account forms.
• Your transactional history with affiliates MB Trading and/or MB Trading Futures, Inc.
• Your account records including transactional history with nonaffiliates Penson Financial Services, Inc. and Penson GHCO, where it is appropriate
• Information from credit reporting agencies (e.g. Experian, Equifax, and Trans Union).
• Current and prior employers, federal and state agencies.
• Consumer reporting agencies such as McDonald Information Service, Inc.

YOUR NONPUBLIC PERSONAL INFORMATION

The type of nonpublic personal information collected varies according to the products or services provided and may include, the following categories: (1) name, (2) current and prior resident addresses, (3) phone number, (4) e-mail address, (5) social security number, (6) securities or futures trading history, (7) date of birth, (8) banking relationships, (9) interest in opening an account, (10) investment experience, (11) total assets, (12) cash balances, (13) margin information, (14) trading positions, (15) account balances, (16) income, (17) excess margin, (18) margin loan records, and (19) deposit and withdrawal history.

Information collected is used to process your transactions, update your account records, to inform you of other services that may be of interest, and to ensure compliance with appropriate regulations.

SECURITY

We limit access to only those employees or representatives that need to know the information in order to assist in carrying out your request for products or services. We have policies and procedures that give direction to our employees, and representatives acting on our behalf, regarding how to protect and use nonpublic personal information. Further, we maintain physical, electronic, and procedural safeguards that comply with federal and state regulations to guard your information.

AFFILIATED COMPANIES

We will share information with affiliates if the information is required to provide a product or service you have requested. Additionally, we may share information with our affiliates about our experiences or transactions with you or your account in order to make you aware of services and products from which you may benefit. Information that may be shared with affiliates include your name, email address, mailing address, age, employment status, general account and demographic information and account history with us.

An affiliate is a company that we own or control or with which there is common ownership with us and our parent company. MB Trading, MB Trading Futures, Inc. and WGAL, LLC are affiliates of each other.

NONAFFILIATED THIRD PARTIES

We do not share nonpublic personal information about you with nonaffiliated third parties, unless otherwise permitted or required by law, which does not aid in the carrying out of your request or instructions. These nonaffiliated third parties include government/regulatory organizations, such as the Internal Revenue Service (IRS), the Securities and Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC), Financial Industry Regulatory Authority (FINRA), National Futures Associations (NFA) and to parties under court order or subpoena that request this information. Disclosures for which you have provided your consent or you have directed us to make are permitted.

We require all entities with which we share your nonpublic personal information agree to keep your information confidential. We also prohibit them from using or disclosing your information except for the limited purpose and to the persons for whom disclosure was intended, or as otherwise permitted by law.

Our privacy policy applies, to the extent required by law, to employees and representatives that act on the firm's behalf. Additionally, we regularly review privacy policies of third parties for administrative services and joint marketing agreements to ensure compliance with appropriate federal and state regulations.

OPT OUT OF DISCLOSURE

The law allows you to "opt out" of our sharing nonpublic personal information about you in certain circumstances with affiliated and nonaffiliated companies; that is, you may direct us to not make such disclosures.

However, we do not currently share information about you with any affiliate or third party that triggers this opt-out right. Therefore, there is no need for you to opt out. If in the future we desire to disclose your information in a way that is inconsistent with this policy, we will notify you in advance and provide you with the opportunity to opt out of such disclosure through one of the options listed below.

If you elect to opt-out of information sharing, it will remain inforce until you tell us to change your choice or for at least five years from when you tell us your choice. Once that period expires, you will receive a renewal notice that will allow you to continue to opt-out of information sharing for at least another five years. You can opt back in at any time. An opt-out election must be made for each account you maintain with us.

Options to opt-out of the sharing of information:

• Contact us by phone at (866) 628-3001
• Login to the secured website and select “Opt-Out of Information Sharing”
• Send an email through the secured customer website to optout@mbtrading.com with the words "Opt-Out of Information Sharing" in the subject line and your MBT account number in the body copy.

USE OF COOKIES TECHNOLOGY

A cookie is a small piece of information that's sent to your browser (along with an HTML page) by our server. When you return, some stored information is sent back to our web server along with your request. A cookie is uniquely yours and can only be read by the server that gave it to you. It cannot read any other part of your files, nor can it be used to send viruses. We will use cookies on our website to authenticate valid accounts and grant access to the secure customer area. The use of cookies is the simplest, most secure, and most widely accepted form of authentication. Security will not be compromised. Using a cookie helps ensure that only you have access to your account. Authentication information is valid only for a single session and changes each time you begin a new session. We only require cookies on our secure website, so they will be transmitted using encryption. Your privacy is of the highest priority. We have worked hard to earn your trust and we will continue to do so. No other company or website can access the cookies. Furthermore, we will use your personal information only to service your account and to improve the quality of our service. We do not sell your personal information to third parties.

PRIVACY POLICY AMENDMENTS

We reserve the right to change our privacy policies and related procedures at any time, in accordance with applicable federal and state laws. In the event that we change our privacy policy, you will be sent an updated copy of the policy by mail or e-mail. Should our policy change regarding the sharing of such nonpublic information, you will receive a copy of the updated notification prior to the sharing of such nonpublic information and you will also be provided with an opportunity to opt out of the information sharing arrangement by mail or e-mail.

DIRECT MARKETING

Did you know that millions of consumers are sent hundreds of pieces of unsolicited commercial advertisement through the mail or contacted by telephone each year? The companies that make use of this type of service are called direct marketers and telemarketers. Many of these companies are members of The Direct Marketing Association (DMA); the oldest and largest trade association for users and suppliers in the direct, database and interactive marketing fields.

If you do not want to receive any commercial communications from the DMA in the future, please let them know by calling Customer Service at (212) 768-7277, by sending an e-mail to customer@the-dma.org, or by writing to the mailing address below.

The Direct Marketing Association
Attn: Customer Service, Opt Out
1120 Avenue of the Americas
New York, NY 10036-6700

When contacting the DMA, please be sure to include complete information about each name, address, and telephone number that you would like to have excluded from their national contact lists. If you have moved within the past year, you should also include your old address and phone number. This is also true for name changes and the addresses and phone numbers associated with each name.

If you have questions regarding our privacy policy, or to update your account information, please call the Customer Service Department at (866) 628-3001.

THIS PRIVACY NOTICE IS PROVIDED TO YOU FOR INFORMATIONAL PURPOSES ONLY. YOU DO NOT NEED TO CALL OR TAKE ANY ACTION IN RESPONSE TO THIS NOTICE. WE RECOMMEND THAT YOU READ AND RETAIN THIS NOTICE FOR YOUR PERSONAL RECORDS.

Effective date: December 8, 2009