Privacy Policy

Privacy Policy

Due to the large number of business plan ideas and related materials that SternAegis reviews, and the similarity of many such plans and materials, we cannot agree to obligations of confidentiality, non-use, or non-disclosure with regard to any information or materials submitted or provided to or otherwise shared with us. By submitting information or materials to SternAegis, you (or anyone acting on your behalf) agree that any such information or materials will not be considered confidential or proprietary, and that SternAegis is free to use it without condition. In no event will SternAegis be limited in, or restricted from, the pursuit of any opportunities, either alone or with third parties.

Pursuant to Title V of the Gramm-Leach-Bliley Act (GLBA) and the U.S. Securities and Exchange Commission (SEC) Regulation S-P (17 CFR 248.1-248.30), we are required to notify you of Aegis Capital Corp.’s (Aegis Capital) Privacy Policy. This disclosure is intended to notify you of the uses we make of the non-public financial and personal information we obtain about you in the course of providing brokerage services for you. Aegis Capital is a New York Corporation with a main office located in New York City, New York. We are an introducing securities broker-dealer, with our transactions clearing through another registered broker-dealer, RBC Correspondent Services (RBC CS), a dvision of RBC Capital Markets, LLC, Apex Clearing Corporation.  You should have received a separate disclosure regarding Ridge Clearing or JPM’s Private Policy. Aegis Capital is registered with the SEC and a member of the Financial Industry Regulatory Authority (FINRA) and the Securities Investor Protection Corporation (SIPC). In order to transact securities business on your behalf, we obtain a variety of non-public financial and personal information about you. In addition, we maintain a record of your securities transactions, which is also non-public. We obtain and maintain records of this information only for the purpose of maintaining the business of being a securities broker-dealer, and in compliance with applicable federal, state and self-regulatory organization rules. NO SALE OF YOUR NON-PUBLIC FINANCIAL AND PERSONAL INFORMATION Aegis Capital DOES NOT SELL YOUR NON-PUBLIC FINANCIAL OR PERSONAL INFORMATION NON-PUBLIC FINANCIAL AND PERSONAL INFORMATION COLLECTED The information collected and maintained by Aegis Capital in transacting securities information on your behalf includes, or may include, the following types of non-public financial and personal information: 1. Information from you: information you provide on new account form(s); whether provided in writing, in person, by telephone or facsimile, via electronic communication or any other means; such as your name, telephone number, address, social security number, tax ID number, assets, income, investment objectives, financial situation, employer, age and previous securities experience. 2. Information about your securities and/or other transactions: (a) information Aegis Capital collects and relates to account(s) balance, payment history, trading activity and any other transactions, which take place through or affect transactions which take place through Aegis Capital; and (b) information Aegis Capital collects as part of servicing your account(s). 3. Information about your transactions with non-affiliated third parties: (a) information from non- affiliated third parties pursuant to law, rules, regulations, standard securities industry practice and/or legal process, including documents received, shared, produced or provided in connection with a subpoena, discovery request or other legal process compelling production; and (b) information from non-affiliated third parties related to servicing your account(s). NON-PUBLIC FINANCIAL AND PERSONAL INFORMATION DISCLOSED TO AFFILIATES AND NON-AFFILIATED THIRD PARTIES Aegis Capital discloses to affiliated and non-affiliated third parties non-public financial and personal information only in connection with the conduct of its securities brokerage business. Such disclosures may include, among other things, information related to transactions, settlement, billing, payment, processing, clearing, transferring, reconciling, collection or tax reporting. Disclosures may be made to affiliates or non-affiliated third parties: (1) as required or necessary to carry out fully and properly the securities business conducted by Aegis Capital (e.g. to service providers supplying document processing and delivery, data maintenance or processing services, RBC CS, Apex Clearing Corporation and to non-affiliated clearing agencies or entities); (2) as required by law or legal process; (3) with your consent; (4) to resolve customer disputes; (5) when requested by a fiduciary or beneficiary on the account; (6) when requested by the client’s attorney(s) or accountant(s); (7) when required by a regulatory agency, or for other reasons required or permitted by law; or (8) in connection with a sale or merger of the firm’s business. FORMER CUSTOMERS The same protections for non-public financial and personal information of current customers of Aegis Capital apply to information regarding former customers: disclosure is made only as permitted/required by law or legal process, or with your consent. CONFIDENTIALITY AND SECURITY OF NON-PUBLIC FINANCIAL AND PERSONAL INFORMATION Aegis Capital is committed to implementing and maintaining commercially reasonable and appropriate measures to maintain the privacy and confidentiality of the non-public financial and personal information we collect and maintain about you. Our procedures for insuring this include, at a minimum, the following: – Access controls on customer information systems, including controls to authenticate and permit access only to authorized individuals, as well as physical access controls. – Policies restricting the provision of non-public financial or personal information to anyone other than the customer over the phone. – Pre-employment screening, including fingerprinting of all employees with responsibilities for or access to non-public financial or personal information. Aegis Capital regularly reviews and may revise, or update its privacy policies and systems at any time, in accordance with changes in technology or legal requirements. OPT-OUT PROVISIONS Since sharing information under the circumstances noted is necessary to service the client account or mandated by competent authority, Aegis Capital does not have any opt-out provisions. SEC REQUIRED REPORT ON ROUTING OF CUSTOMER ORDERS In compliance with SEC Rule 11Ac1-6 requiring all brokerage firms to make publicly available quarterly reports on the routing of non-directed orders, please access Aegis Capital’s website at under the “SEC Disclosure Rule” section to obtain this information. In addition, upon your request, Aegis Capital will provide you with the name of the market center or exchange a specific order was routed for execution. The specific order must have been processed within the past six (6) months from the date of your request. Please contact Operations at (212) 813-1010. CUSTOMER COMPLAINTS Please be advised that any customer complaint can be made in writing and directed to:

Attn: Compliance Department Aegis Capital Corp. 810 Seventh Ave., 11th Floor New York, NYÂ 10019

or by facsimile to the attention of Compliance (212) 813-1047

Brokerage and investment advisory products and services, are offered through Aegis Capital Corp, a member of FINRA and SIPC. Insurance products are made available through, ACC General Agency, a licensed insurance agency. For those persons inquiring from states where a specific associate is not currently securities and/or insurance licensed, the associate will not transact business in that state or provide follow-up individual responses, until after the associate obtains the appropriate registration in the applicable state.

The information provided should not be relied upon in isolation for the purpose of making an investment decision. You must also consider the objectives, risks, charges, and expenses associated with an investment service, product or strategy prior to making an investment decision. Prior to making any investment or financial decision, an investor should seek advice from a financial, legal, tax and other professional that consider all of the particular facts and circumstances of an investor's situation. The opinions expressed and material provided are for information purposes only and is not an offer, recommendation, or solicitation of any product, strategy or transaction. Any views, strategies or products discussed may not be appropriate or suitable for all individuals and are subject to risks.

Investment and insurance products offered are not insured by the FDIC or any other federal government agency, are not deposits or other obligations of, or guaranteed by, a bank or any bank affiliate, and are subject to investment risks, including possible loss of the principal amount invested.

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