Privacy Statement

Who is covered by the Privacy Policy

This Privacy Policy applies to all clients.

Our Commitment to Privacy

Inevitably, Excel Management collects information about you from various sources. Excel Management are committed to maintaining the confidentiality, integrity, and security of personal information about our current and prospective customers.
We are very serious about protecting the privacy of our customer information. We maintain safeguards that comply with international standards to store and secure information we have about you. The safeguards may be physical, electronic or procedural. The safeguards protect information against unauthorized access, alteration and destruction. We have control policies that permit access to customer information only by people we believe need access to do their work.

How and why we obtain personal information

Excel takes great care to protect personal information about you and when we use it, we do so with respect for your privacy. We may use personal information about you to service and maintain your account; process transactions in your account; respond to inquiries from you or your representative; develop, offer, and deliver products and services; or to fulfill legal and regulatory requirements. Excel may collect public and non-public personal information about you from any of the following sources:
• You or your representative on applications or forms (for example, name, address, Social Security number, birth date, assets and income)
• Transactional activity in your account (for example, trading history and balances)
• Other interactions with Excel (for example, discussions with our customer service staff or information you enter into our websites)
• Other sources with your consent or with the consent of your representative (for example, from other institutions if you transfer positions into Excel)

How we protect information about you

Excel 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.
At Excel, we restrict access to personal information to those who require it to support, offer and deliver products and services to you.

How we share information about you with third parties

Excel does not share personal information about our customers with any third party for use in marketing their products and services. We do not enter into contracts with other companies to provide services to us or make products and services available to you.

We may share personal information with the following entities:

• Unaffiliated service providers (for example, securities clearing-houses, marketing service providers, and other entities who may provide services at Excel’s direction)
• Government agencies, other regulatory bodies and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions)
• Other organizations, with your consent or as directed by your representative (for example, if you use Excel as a financial reference in applying for credit with another institution), or as permitted or required by law (for example, for fraud prevention)
• If you conduct business with Excel through your investment professional, we may exchange information we collect with your investment professional or with others they may authorize.
Our service providers are obligated to keep the personal information we share with them confidential and use it only to provide services specified by Excel.

How we share information about you within Excel

If you interact with Excel directly as an individual investor (including joint account holders), we may share personal information about you with various Excel corporate affiliates including internal service providers which perform, for example, printing, mailing, and data processing services.
Information collected from investment professionals’ customers is not shared with Excel affiliates for marketing purposes, except with your consent and as allowed by law.

Privacy online
Privacy, security, and service in Excel’s online operations are just as critical as in the rest of our business. We use firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of your online session and to protect Excel accounts and systems from unauthorized access.
When you interact with us through online channels (for example, websites and mobile applications) owned and controlled by Excel, we manage personal information in accordance with all of the practices and safeguards described previously.
When you visit Excel websites, we may collect technical and navigational information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on Excel websites … and use this information for a variety of purposes, such as maintaining the security of your online session, facilitating site navigation, improving Excel website design and functionality.
Cookies and similar technologies
We use cookies and similar technologies to support the operation of Fidelity websites. You can refuse or delete cookies. Most browsers and mobile devices offer their own settings to manage cookies. If you refuse a cookie when on a Fidelity website, or if you delete cookies, you may experience some inconvenience in your use of an Excel websites. 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.

Protecting children’s privacy online

Excel websites are not directed to individuals under the age of thirteen (13). Fidelity does not intentionally collect information on Excel websites from those we actually know are under 13, and we request that these individuals do not provide personal information through the sites.

Additional information

If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current customers.
You may also write or call us with your request for information. If we served you through an investment professional, please ask to speak to them directly. Specific Internet addresses, mailing addresses and telephone numbers are listed on your statements and other correspondence.

Please note that certain details of this policy may depend on whether you deal with us directly as an individual investor or through an investment professional.

The privacy policies of Excel Management are reviewed annually. Our printed and online notices are then updated to reflect any changes.