Privacy Policy

WHAT DOES HEALTHIOS CAPITAL MARKETS 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.

As required by Federal Regulation S-P and Regulation S-AM, Healthios Capital Markets is issuing this privacy disclosure to you so that you know our means of governing the privacy of your financial information.

What?

The types of personal information we collect and share can include:

  • Social Security number and income
  • Account balances
  • Transaction information
  • Investor Capital Structure Information, Issuer’s Client data and other proprietary information

How?

All financial companies need to share clients’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their clients’ personal information; the reasons Healthios Capital Markets might choose to share; and whether you can limit this sharing.

As a means of providing you with service, we collect certain non-public information about you from information you provide on applications and other forms and information about your transactions with us. We may also collect such information through questionnaires provided directly to you by us, through direct inquiries by mail or telephone, or indirectly from third parties with your permission.

Reasons we can share your personal informationDoes Healthios share?Can you limit this sharing?
For our everyday business purposes - Such as sending data to Healthios affiliates, Healthios Thailand, to create executive summariesYesNo
For our marketing purposes - To offer your securities to the investment communityYesNo
For joint marketing with other financial companiesNo-
For our affiliates' everyday business purposes -Information about your transactions and experiencesYesNo
For our affiliates' everyday business purposesNo-
For our affiliates to market to youNo-
For non-affiliates to market to youNo-

Questions?

If you have questions about our privacy policy, you can contact us at (847) 400-5000.

Who we are

Healthios Capital Markets, LLC – A Licensed Securities Broker-Dealer and member firm of FINRA and SIPC.

What we do

How does Healthios Capital Markets protect my personal information?
Healthios Capital Markets restricts access to your personal account information internally to those employees who need to know that information to provide products and services to you. We also maintain physical, electronic and procedural safeguards to protect your nonpublic personal information. We will adhere to the privacy policies and practices as described in this notice regardless of your account status or level of activity.

How does Healthios Capital Markets collect my personal information?
We collect your personal information, for example when you

  • When you sign an engagement agreement
  • Through inquiry provided directly to you by us

Why can't I limit all sharing?
Federal Regulation S-AM gives you the right to limit only

  • Sharing for affiliates’ everyday business purposes-information about your credit worthiness
  • Affiliates from using your information to market to you
  • Sharing for nonaffiliates to market to you

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

Definitions

Affiliates: Healthios Thailand Pte is an affiliate of Healthios Capital Markets, LLC. Healthios Thailand Pte and Healthios Capital Markets are wholly owned subsidiaries of Healthios Holdings, LLC.

Nonaffiliates: Companies not related by common ownership or control.

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

Other Important Information

Internet
Healthios Capital Markets does not assume any responsibility for the loss of privacy of any information about you exchanged via the Internet between you, Healthios Capital.

Information Disclosed in Administering Products and Services
With respect to your personal and financial matters, Healthios Capital Markets neither sells or discloses nonpublic personal information regarding our clients or former clients, except as required by law. Specifically, we do not sell client lists or any other client information to outside companies. In an effort to help you meet needs and to effect transactions you request or authorize, we may disclose the information we collect about you to financial service providers such as investors, marketing service providers such as printers and mailers. These companies use this information only for the services for which we hire them, and they are not permitted to use or share this information for any other purpose.

9   CONFIDENTIALITY; REGULATION S-P (as addressed in the Healthios Capital Market’s Written Supervisory Procedures)

9.1 General.

9.1.1 Confidentiality Policy. The Firm is required to collect private financial information about its customers and prospective customers to satisfy its “know your customer” obligation. The Firm will know what transactions have been effected for the customer and other information about the financial circumstances of the customer. It is the Firm’s policy not to disclose this type of information except under the following circumstances: as requested or instructed by the customer; to personnel of the Firm, to enable them to provide services to the customer; to third-party service providers to enable them to provide services necessary to carry out the instructions of customers or the Firm’s obligations to customers; to facilitate the processing of transactions for customers; as required by law, for example, in response to an inquiry by the SEC or FINRA or a court subpoena; to the Firm’s legal counsel, or to its independent auditor, as may be required for audit purposes or for legal advice.

The Firm does not sell or rent its customer lists.

These policies apply to former customers, as well as current customers and to persons who have submitted information to the Firm with a view to entering into a business relationship with the Firm. See "Privacy Notice" below.

9.1.2 Confidentiality of Electronic Data. The Firm collects and maintains on its computer confidential records and information about the Firm’s customers. The Firm has appropriate firewalls to prevent unauthorized access to the Firm’s records. If, in the future, the Firm considers upgrading its computer system, it will ensure that any new technology that the Firm is reviewing, will not breach its firewalls. Under no circumstances will the Firm consider Wireless Fidelity or similar technology that is known to be easily accessed by “hackers.”

In addition, e-mail and instant messages transmitted via the Firm’s computer system are captured, archived and copied to and stored on a server maintained by Smarsh. The electronic applications installed by Smarsh contain appropriate firewalls to prevent unauthorized access to the archived communications. In the event that the Firm considers new technology to upgrade or replace its current e-mail and instant messaging systems, the Firm will ensure that any new technology under consideration contains equal, or advanced if available, security features.

9.2 Restrictions on Associated Persons. Associated Persons of the Firm must not disclose any private financial information about a customer to any other firm or person, except as permitted by the policy stated above. See “Privacy Notice” below.

9.3 Privacy Notice. As required by SEC Regulation S-P, the Firm will send a privacy notice, to each new “consumer” and “customer,” as defined in Regulation S-P, informing the consumer or customer of the Firm’s policies with respect to confidential treatment of nonpublic personal information.

For purposes of this notification requirement:

a “consumer” is an individual including his IRA (but not an entity) who gives personal financial information to the Firm with a view to becoming a Client of the Firm. Since the Firm is a private placement agent, it does not have “consumers”

a “customer” is an individual including his IRA (not an entity) who has established an ongoing business relationship with the Firm as a Client. Also, a “customer” is defined as an investment banking client that has engaged the Firm to be its financial advisor in representing them as an issuer of new securities under Regulation D or PIPE transaction.

As defined by the terms above, the Registered Representative is responsible for providing the required notice at the beginning of the relationship (i.e., when a person applies to open an account and/or become a Customer), and at least annually thereafter to each Customer with which the Firm has a continuing relationship (i.e., to each Customer that is also a “customer”). The required notice will be in substantially the form as contained below. All privacy notices that are returned to the Firm must be forwarded to the Firm’s Compliance Function.

If a consumer/customer returns the notice and opts out of the parts authorizing the Firm to share his information with affiliates and/or third parties, the Firm’s Compliance Function will note this in the Firm’s records and is responsible that compliance with the opt out exercise is honored.

9.4 Disposal of Consumer Report Information. In the event the Firm engages in the “Disposal” of “Consumer Report Information” (as these terms are defined below), the Firm will take reasonable measures to dispose of this information properly -- i.e., to protect against unauthorized access to or use of the information in connection with its Disposal. The Firm’s Compliance Function will train employees in the requirements of Regulation S-P; instruct employees to burn, pulverize, or shred papers and to destroy or erase electronic media containing Consumer Report Information so that the information cannot be read or reconstructed; at least annually monitor the destruction of this information; and take such other reasonable measures to protect the information against unauthorized access or use as he deems appropriate. Such measures may also include, but are not limited to, the following:

After due diligence, entering into a contract with another party engaged in the business of record destruction to dispose of material specifically identified as Consumer Report Information, in a manner consistent with Regulation S-P; and

If the Firm has Consumer Report Information due to its provision of services directly to a person subject to the disposal requirements of Regulation S-P, implementing and monitoring procedures that protect against unauthorized or unintentional disposal of Consumer Report Information.

The foregoing procedures do not alter or affect any records requirements imposed on the Firm under any other provisions of law.

As used in this Section 9:

“Consumer Report” means any written, oral, or other communication of any information by a consumer reporting agency bearing on a consumer’s credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living which is used or expected to be used or collected ... for the purpose of serving as a factor in establishing the consumer’s eligibility for personal, family or household credit; employment purposes; or any other purpose under Section 604 of the Fair Credit Reporting Act. This term has the same meaning as in section 603(d) of such Act (15 USC 1681(a)(d)).

“Consumer Report Information” means any record about an individual, whether in paper, electronic, or other form, that is a Consumer Report, is derived from a Consumer Report, or is a compilation of these records. Consumer Report information does not include information that does not identify individuals, such as aggregate information or blind data.

“Disposal” means the discarding or abandonment of Consumer Report Information, or the sale, donation, or transfer of any medium, including computer equipment, on which Consumer Report Information is stored.

“Private Financial Information” means information a customer or prospective customer provides (i) resulting from any transaction for or with that customer; or (ii) that the Firm obtains about a consumer in connection with providing a financial product or service to that customer.

9.5 Safeguarding Consumer Records and Information1. To the extent the Firm maintains access to Consumer Report Information or other private financial information about customers or prospective customers that has not been disposed of as provided above, the Firm will maintain, and the Firm’s Compliance Function will enforce, the following procedures:

If this information is maintained in paper format:

The Firm’s Compliance Function will instruct all Associated Persons that any documents containing private financial information about customers must be kept in locked file cabinets located in the Main Office.

Only those persons who the Firm’s Compliance Function has determined have a legitimate business reason to have access to such information will have keys or codes that unlock the file cabinets.

The Firm’s Compliance Function will keep a written or electronic record of all persons who have keys or codes that unlock the file cabinets.

If this information is maintained electronically:

The Firm’s Compliance Function will instruct all Associated Persons that any files containing private financial information must be password protected.

Only those persons who the Firm’s Compliance Function has determined have a legitimate business reason will be given password access to this information.

The Firm’s Compliance Function will keep a written or electronic record of all persons who have password access to such information.

At least annually, the Firm’s Compliance Function will review the maintenance of the files containing information subject to this Section and will implement additional procedures to address any potential security breaches as the need may arise.

A Registered Representative will notify the Firm’s Compliance in the event of any breach of security implicating the personal information of any consumer/customer, and the Firm’s Compliance Function will consult with counsel regarding the applicability of state or federal requirements, including notification to the consumer/customer affected or potentially affected.

Special stringent restrictions that vary state by state apply to the privacy of Social Security numbers. If the Firm plans to share the Social Security number of a consumer/customer for any purpose other than effecting, administering, or enforcing a transaction requested or authorized by the consumer/customer or in connection with servicing or processing a financial product or service requested or authorized by the consumer/customer, contact Mission Critical Services Corp. for additional procedures needed for compliance with the state in which the transaction is effected
Regulation S-P; SEC Rel. No. 34-50781

Several states require prompt notice to their residents affected by a hacking of the Firm’s computer records. When the Firm’s Compliance Function learns of or determines that a hacking of the computer records of the Firm or its clearing agent has occurred, the Firm’s Compliance Function will contact its counsel to determine what steps to take next.