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E*TRADE FROM MORGAN STANLEY


PRIVACY STATEMENT

Last updated: January 1, 2022

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PRIVACY STATEMENT

This Privacy Statement ("Statement") covers the following affiliated companies
in the E*TRADE family of companies: E*TRADE Securities LLC, E*TRADE Futures LLC,
E*TRADE Capital Management, LLC, and E*TRADE Financial Corporate Services, Inc.
(including products and services branded with Gradifi). Together, these entities
are referred to as “E*TRADE,” "our affiliates," "we," "us," and "our" in this
Statement.


WE CARE ABOUT YOUR PRIVACY.

We are committed to maintaining the privacy and confidentiality of your personal
information. This Statement explains what personal information we collect about
you, how we use and share that information, and the rights you have in
connection with that information, including how you can limit certain uses and
sharing of your information. Certain rights, requirements, and disclosures in
this Statement may be subject to exemption or otherwise may not apply to you
based, for example, on applicable law or regulations. This information is
required by law and is not a promotion of E*TRADE’s products and services

Personal information that we collect from or about you when you apply for or
obtain an E*TRADE financial product or service for personal, family or household
purposes is also governed by a separate notice entitled E*TRADE Consumer Privacy
Notice. Except as noted below, if you are a current or former applicant or
customer of E*TRADE, please refer to that notice, which is incorporated into and
part of this Privacy Statement, for additional information about our privacy
practices.

You may apply for or obtain a Morgan Stanley Private Bank, National Association
(“MSPBNA”) financial product or service through the E*TRADE website or mobile
applications. Personal information that we collect from or about you in
connection with an MSPBNA financial product or service is shared with MSPBNA and
is governed by this Statement with respect to E*TRADE’s provision of services to
MSPBNA and by the Morgan Stanley U.S. Privacy Policy and Notice and the Morgan
Stanley Wealth Management U.S. Consumer Privacy Notice with respect to MSPBNA’s
role as your financial product or service provider.

Personal information that we collect about you when you apply for a job at
E*TRADE or when you act as an employee or contractor at E*TRADE is governed by a
separate notice, which will be provided to you at or before the time your
personal information is collected.


1. INFORMATION WE COLLECT

As described in this Statement, we may collect personal information from or
about you in order to provide, enhance, market, and offer our products and
services,including the products and services of our Morgan Stanley affiliates
(together, “Services”) to you and to our institutional clients. “Services”
include, among other things, maintaining or servicing accounts, providing
customer service, processing or fulfilling trades and other transactions,
verifying customer information, processing payments, providing financing,
determining eligibility for Services, recordkeeping, and related activities.

This section describes the categories of personal information we may collect,
including personal information we have collected in the past twelve months. For
purposes of this Statement, personal information generally includes information
that may be used to identify you. You are not required to give us all the
personal information identified in this Statement; however, if you do not
provide requested personal information, we may not be able to provide you with
some or all of the Services. We only collect personal information in accordance
with applicable law.

Categories of Personal Information We Collect Examples of Personal Information
We Collect Identifiers Name, alias, home and work addresses, home and work phone
numbers, mobile phone number, Social Security number, driver’s license number,
passport number, tax identification number, other government-issued
identification numbers, alien registration number, date of birth, email address,
username and password, social media name, signature, customer identification
number, IP address, electronic device (“Device”) identifier, device type,
browser type, platform type, cookies, pixels, and beacons Financial information
Financial account number, credit card number, debit card number, account
balance, trading activity, transactions, equity compensation, loan number, loan
amount, 529 plan account number, account history, income, debt, assets, revenue,
credit history, credit score, investment experience, risk tolerance, and
information about your personal investment goals or objectives Protected
classifications under California or federal law (“Protected Class Information”)
Age, sex, gender, national origin, citizenship, race, ethnicity, marital status,
and disability status Commercial information Records of personal property, and
order and purchase history for non-financial goods and services Biometric
information Fingerprint, palm scan, and voiceprint Internet or similar network
activity Browsing history, search history, clickstream data, session
information, navigation paths, and other information about how you interact with
our websites and mobile applications Geolocation data Physical location or
movements Sensory data Audio recordings, video recordings, and photographs
Professional or employment-related information Employment information (including
employer name), employment history, professional licenses or registrations, and
employment identification number Education information Academic record, degrees
and schooling Inferences from other personal information Preferences, behaviors,
characteristics (including, for example, age gender, race, and marital status),
number of persons in household, location, income, assets, accounts, funds,
investments, and similar information

In addition, we may compile aggregate, anonymous, or de-identified data from
various sources, including, but not limited to, accounts and transactions. This
data, which we may use for our business purposes consistent with applicable law,
does not identify an individual and is not personal information.


2. SOURCES OF INFORMATION AND PURPOSES OF COLLECTION AND DISCLOSURE

This section describes the sources we may collect personal information from and
why we may collect and, if applicable, share personal information.

Sources of Personal Information Categories Personal Information We Collect
Purpose of Collecting and Sharing Personal Information

Applications and Forms

We may collect personal information from you or your authorized representatives
during the application or account creation process, through other forms, or
through discussions we have with you or your authorized representatives.

 * Identifiers
 * Financial information
 * Protected Class Information
 * Professional or employment-related information

 * Provide the Services
 * Market, advertise, and promote the Services
 * Protect against unauthorized access, security incidents, fraud, and other
   malicious or illegal activity
 * Comply with legal and regulatory obligations, and to establish, enforce, and
   otherwise exercise our rights and defend against claims

Communications and Interactions with Us

We may collect personal information from you or your authorized representative
when you communicate with us, including when you contact customer support,
submit inquiries, request information from us, provide feedback, or participate
in a promotion, contest, survey or conference.

 * Identifiers
 * Financial information
 * Protected Class Information
 * Sensory data

 * Provide the Services
 * Enhance the Services
 * Market, advertise, and promote the Services
 * Protect against unauthorized access, security incidents, fraud, and other
   malicious or illegal activity
 * Comply with legal and regulatory obligations, and to establish, enforce, and
   otherwise exercise our rights and defend against claims

Transaction Activity

We may collect personal information from you and from records we create about
you when you make transactions with or through us.

 * Identifiers
 * Financial information

 * Provide the Services
 * Enhance the Services
 * Maintain system and process functionality
 * Protect against unauthorized access, security incidents, fraud, and other
   malicious or illegal activity
 * Comply with legal and regulatory obligations, and to establish, enforce, and
   otherwise exercise our rights and defend against claims

Our Websites and Mobile Applications

We may collect personal information from your Device when you visit or interact
with our websites or mobile applications.

 * Identifiers
 * Internet or similar network activity
 * Geolocation data

 * Provide the Services
 * Enhance the Services
 * Maintain system and process functionality
 * Market, advertise, and promote the Services
 * Protect against unauthorized access, security incidents, fraud, and other
   malicious or illegal activity
 * Comply with legal and regulatory obligations, and to establish, enforce, and
   otherwise exercise our rights and defend against claims

Social Media and Online Forums

We may collect personal information from third-party social media platforms and
sites, when you engage with our social media pages, online communities and
forums, and when you mention us on your own or other social media pages, online
communities or forums. Please note that online forums may be publicly accessible
and other users may view information you post in the forums. We encourage you to
exercise care in deciding what information and content you wish to disclose on
the areas of the website that are accessible to the general public.

 * Identifiers
 * Internet or similar network activity

 * Provide Services
 * Enhance the Services
 * Market, advertise, and promote the Services
 * Comply with legal and regulatory obligations, and to establish, enforce, and
   otherwise exercise our rights and defend against claims

Our Physical Sites

We may collect personal information both directly and indirectly from you when
you visit our branches, offices, and other physical locations (“Sites”).

 * Biometric information
 * Sensory data

 * Protect against unauthorized access, security incidents, fraud, and other
   malicious or illegal activity
 * Comply with legal and regulatory obligations, and to establish, enforce, and
   otherwise exercise our rights and defend against claims

Stock Plan and Employee Benefit Services

We may collect personal information from your employer if your employer uses our
technology and Services to administer its stock plan or other employee benefits
or perks.

 * Identifiers
 * Financial information
 * Protected Class Information
 * Professional or employment -related information

 * Provide the Services
 * Maintain system and process functionality
 * Market, advertise, and promote the Services
 * Protect against unauthorized access, security incidents, fraud, and other
   malicious or illegal activity
 * Comply with legal and regulatory obligations, and to establish, enforce, and
   otherwise exercise our rights and defend against claims

Advisor Services

We may collect personal information from your registered investment advisor
(“RIA”) if your RIA uses our technology and Services to administer and manage
your assets.

 * Identifiers
 * Financial information
 * Protected Class Information
 * Commercial information
 * Professional or employment-related information
 * Education information

 * Provide the Services
 * Market, advertise, and promote the Services
 * Maintain system and process functionality
 * Protect against unauthorized access, security incidents, fraud, and other
   malicious or illegal activity
 * Comply with legal and regulatory obligations, and to establish, enforce, and
   otherwise exercise our rights and defend against claims

Affiliates

We may collect personal information from our affiliates including, for purposes
of this section, our Morgan Stanley affiliates.

 * Identifiers
 * Financial information
 * Protected Class Information
 * Commercial information
 * Biometric information
 * Internet or similar network activity
 * Geolocation data
 * Sensory data
 * Professional or employment-related information
 * Education information
 * Inferences

 * Provide the Services
 * Market, advertise, and promote the Services (unless you opt out)
 * Maintain system and process functionality
 * Protect against unauthorized access, security incidents, fraud, and other
   malicious or illegal activity
 * Comply with legal and regulatory obligations, and to establish, enforce, and
   otherwise exercise our rights and defend against claims

Service Providers, Data Brokers, and Business Partners

We may collect personal information from service providers and business
partners.

 * Identifiers
 * Financial information
 * Commercial information
 * Protected Class Information
 * Biometric information
 * Internet or similar network activity
 * Geolocation data
 * Sensory data
 * Professional or employment-related information
 * Education information
 * Inferences

 * Provide the Services
 * Market, advertise, and promote the Services (unless you opt out)
 * Maintain system and process functionality
 * Protect against unauthorized access, security incidents, fraud, and other
   malicious or illegal activity
 * Comply with legal and regulatory obligations, and to establish, enforce, and
   otherwise exercise our rights and defend against claims

Government Entities

We may collect personal information from government agencies, regulators,
securities, futures and commodity exchanges, and self-regulatory bodies
(“Government Entities”).

 * Identifiers
 * Financial information
 * Protected Class Information
 * Biometric information
 * Internet or similar network activity
 * Geolocation data
 * Sensory data
 * Professional or employment-related information
 * Education information

 * Provide the Services
 * Protect against unauthorized access, security incidents, fraud, and other
   malicious or illegal activity
 * Comply with legal and regulatory obligations, and to establish, enforce, and
   otherwise exercise our rights and defend against claims

Consumer Reporting Agencies

We may collect personal information from consumer reporting agencies.

 * Identifiers
 * Financial information
 * Protected Class Information
 * Inferences

 * Provide the Services


3. INFORMATION WE MAY SHARE AND WHO WE MAY SHARE IT WITH

This section describes the categories of personal information we may share,
including personal information we have shared in the past twelve months, and the
parties we may share it with. We may share your personal information for the
purposes described in Section 2, when you have provided your consent for
disclosure, or as otherwise permitted or required by law. We do not sell
personal information and have not sold personal information in the past twelve
months.

Categories of Third Parties with Whom We Share Personal Information Categories
of Personal Information We May Share

Operational Service Providers

We may share your personal information with service providers that help us
perform the Services, including, for example, companies that provide
administrative, telecommunications, system, software, trade execution, payment,
and securities clearing services, and that prepare and send account statements
and transaction confirmations and other services in connection with the
operation of our business.

 * Identifiers
 * Financial information
 * Commercial Information
 * Protected Class Information
 * Biometric Information
 * Sensory Data
 * Professional or employment-related information

Security Service Providers

We may share personal information with service providers that detect, protect
against, and respond to security incidents or other malicious, deceptive,
illegal or fraudulent activity or actual or potential threats to the safety or
well-being of any person.

 * Identifiers
 * Financial information
 * Biometric Information
 * Internet or similar network activity
 * Geolocation data
 * Sensory Data

Marketing and Advertising Firms

We may share personal information with service providers that perform marketing,
advertising or market research on our behalf or help us determine the
effectiveness of our marketing.

 * Identifiers
 * Financial information
 * Internet or similar network activity
 * Geolocation data
 * Inferences

Data Analytics Firms

We may share personal information with service providers that perform data
analytics to help us improve our Services and develop new offerings, among other
things.

 * Identifiers
 * Financial information
 * Commercial Information
 * Protected Class Information
 * Internet or similar network activity
 * Geolocation data
 * Inferences

Government Entities

We may share personal information with Government Entities and law enforcement
officials. In certain cases, laws and regulations may require us to share
personal information with these entities.

 * Identifiers
 * Financial information
 * Protected Class Information
 * Biometric Information
 * Internet or similar network activity
 * Geolocation data
 * Sensory Data
 * Professional or employment-related information
 * Education Information

Consumer Reporting Agencies

We may share personal information with consumer reporting agencies.

 * Identifiers
 * Financial information

Professional Service Firms

We may share personal information with professional services firms that help us
comply with our legal and regulatory obligations and establish, enforce, and
otherwise exercise our rights and defend against claims, including, for example,
auditors, law firms, and consultants.

 * Identifiers
 * Financial information
 * Protected Class Information
 * Commercial Information
 * Internet or similar network activity
 * Geolocation data
 * Sensory Data
 * Professional or employment-related information

Institutional Clients

We may share personal information with our institutional clients, including RIAs
and corporate entities that use our technology to administer their stock or
other employee benefit plan(s).

 * Identifiers
 * Financial information
 * Protected Class Information

Business Partners

We may share personal information with business partners.

 * Identifiers
 * Financial information
 * Commercial information
 * Protected Class Information

Affiliates

We may share your personal information with our affiliates including, for
purposes of this section, our Morgan Stanley affiliates (unless you opt out of
eligible sharing).

 * Identifiers
 * Financial information
 * Protected Class Information
 * Commercial Information
 * Biometric Information
 * Internet or similar network activity
 * Geolocation data
 * Sensory Data
 * Professional or employment-related information
 * Education Information
 * Inferences

Merger and Acquisition Activity

We may share your personal information with third parties in connection with the
proposed or actual financing, insuring, sale, securitization, assignment, or
other disposal of all or part of our business or assets (including accounts) for
the purposes of evaluating and performing the proposed transaction.

 * Identifiers
 * Financial information
 * Commercial Information
 * Internet or similar network activity
 * Professional or employment-related information


4. USE OF COOKIES AND SIMILAR TECHNOLOGIES AND INTEREST-BASED ADVERTISING

4.1 COOKIES AND SIMILAR TECHNOLOGIES

We and our third-party service providers may use cookies and similar
technologies on our website and mobile applications to improve user experience,
for performance and analytics, and to improve our content, products, and
services. We also use cookies and similar technologies for purposes of marketing
and advertising, including interest-based advertising. For more information on
interest-based advertising, see the “Interest-Based Advertising” section.
Certain information may be stored or accessed using tracking technologies such
as “cookies” and “web beacons” that may be downloaded to your Device when you
visit or interact with our websites and mobile applications. This information
may include, but is not limited to:

 * IP address, UDID or other unique device identifier, a number that is
   automatically assigned to your Device and used by us to identify your Device;
 * Device functionality and characteristics (including browser, operating
   system, hardware, and mobile network information);
 * The URL that referred you to our website;
 * The areas within our website or mobile application that you visit and your
   activities, including remembering your preferences; and
 * Device location.

A “cookie” is a small text file that a web server stores in browser software. A
browser sends cookies to a server when the browser makes a connection to the
server (for example, when requesting a web page from the same domain that
created the cookie). The purpose of cookies is to remember the browser over time
and distinguish one browser instance (or user) from all others. We use both HTML
cookies and Local Shared Objects (sometimes referred to as Flash cookies) that
are built for use with the Adobe® Flash® Player for authentication purposes and
to enhance navigation and website functionality. Cookies can remember login
information, preferences, and similar information. If you access your account
online, cookies may be used to verify your identity, to authenticate you as a
user on our system and to personalize aspects of your experience on our website.
We also use cookies to let us know how our customers and other visitors are
using our website so that we can optimize their experience. We permit certain
third party advertising providers to set cookies and use related technology such
as web beacons or “clear GIFs” through our website and other websites on which
we advertise, and via HTML email messages, to track performance of
advertisements and to collect aggregate data on web page viewing.  Some cookies
and other technologies may serve to track personal information previously
entered by a web user on the site. We may also use web beacons or “pixels,” and
in certain circumstances may collect IP address, screen resolution and browser
software and operating system types, clickstream patterns, dates and times that
our site is accessed, and other categories of data.

Most browsers allow you to control cookies, including whether to accept them and
how to remove them. You can manually delete HTML cookies and set most browsers
to refuse to accept HTML cookies. For information on how to disable cookies,
refer to your browser’s documentation. Flash cookies may be removed by managing
your Adobe® Flash® Player settings. To delete or prevent placement of Flash
cookies, visit the Adobe® Flash® Player Help site at
www.adobe.com/go/settingsmanager, click on the hyperlink for "Website Privacy
Settings Panel" on the left side of the screen, and follow the instructions for
preventing third party Flash content from storing data on your computer. If you
choose to erase or block your cookies, doing so may affect your website
experience, and certain parts of our website may not function correctly.

Additional information about tracking technologies can be found on our website.
Visit the Security Center and select Information about Tracking Technologies.

 

4.2 INTEREST-BASED ADVERTISING

We use "interest-based" ads, also known as “online behavioral advertising."
Interest-based advertising is advertising that is targeted to you based on your
web browsing and app usage over time and across websites or apps. You have the
option to restrict the use of information for interest-based advertising and to
opt-out of receiving interest-based ads. We may partner with ad networks and
other advertising providers (“Advertising Providers”) who serve ads on behalf of
us and others on non-affiliated sites. Some of these third parties may use
cookies and other technologies to collect information about your online
activities over time and across third party websites or online services to
deliver advertising based on your interests and preferences, as inferred from
your browsing history. Some of these ads may be personalized, meaning that they
are intended to be relevant to you based on information that E*TRADE and its
Advertising Providers collect about your visits to this site and elsewhere over
time.

To learn more about this type of advertising and how to opt-out of this form of
advertising, you may either visit www.aboutads.info to opt-out of sites and
services participating in the Digital Advertising Alliance (“DAA”)
self-regulatory program, or visit www.networkadvertising.org/choices/ to opt-out
of this form of advertising by members of the Network Advertising Initiative
(“NAI”). Note that electing to opt-out will not stop advertising from appearing
in your browser or applications, although it may make the ads you see less
relevant to your interests. In addition, if you use a different browser or erase
cookies from your browser, you may need to renew your opt-out choice.

 

4.3 DO NOT TRACK

Do-Not-Track is a public-private initiative that has developed a “flag” or
signal that an Internet user may activate in the user’s browser software to
notify websites that the user does not wish to be “tracked” by third-parties as
defined by the initiative. Our websites do not alter their behavior when we
receive a “Do Not Track” signal from browser software. Currently, we do not
monitor or take any action with respect to these signals or other similar
mechanisms.


5. HOW TO EXERCISE YOUR RIGHTS

In certain cases, you may be able to limit the types of communications you
receive and certain sharing of your personal information. This section describes
how to exercise those rights.

 

5.1 UPDATING YOUR INFORMATION

As a customer, you may access and update some of your personal information by
logging onto our website using your username and password and, from the home
page, clicking on Account Preferences under the Accounts tab and selecting the
information you want to change. If you believe that your personal information is
inaccurate, incomplete, or out-of-date, you also may contact us using the
information in the “Contact Us” section of this Statement.

 

5.2 LIMITING DIRECT MARKETING

If you would like to stop receiving newsletters or other marketing or
promotional messages, notifications, or updates from us, you may follow the
unsubscribe instructions that appear in these e-mail communications or you may
opt out by contacting us through the information in the “Contact Us” section of
this Statement. You may not be able to opt out of receiving certain service or
transactional messages from us, including, for example, legal notices.

 

5.3 LIMITING CERTAIN SHARING WITH AFFILIATES

We may share certain information about you, including certain creditworthiness
information, with our affiliates, including for purpose of this section, our
Morgan Stanley affiliates, for their everyday business purposes or so they can
market their Services to you. You may opt out of sharing for marketing purposes
and/or sharing creditworthiness information for everyday business purposes by
contacting us through the information in the “Contact Us” section of this
Statement. You may change your opt-out status at any time. For consumers with
joint accounts, an opt out by one joint account holder will be treated as an opt
out by all associated joint account holders. We will process your request in
compliance with applicable laws and regulations and our policies and procedures.
Before responding to certain requests, we may ask you for additional information
to verify your identity.


6. INFORMATION ON INDIVIDUALS UNDER 18 YEARS

We do not knowingly collect information from individuals under the age of 18
years without parental consent. If you become aware that an individual under 18
years of age has provided us with personal information without parental consent,
please contact us using the information in the “Contact Us” section of this
Statement. If we become aware that an individual under 18 years has provided us
with personal information without parental consent, we will take steps to remove
the data as permitted by law.


7. LOCATION OF DATA STORAGE AND PROCESSING

The personal information we collect from you will be stored in the United States
and may be stored in other countries that may have different privacy laws and
standards than those in your country of residence. Your personal information may
be transferred to or processed in the United States by us or by a third-party
service provider working for us. If you are located outside of the United
States, the transfer of personal information is necessary to provide you with
the requested information, products, and services and/or to perform any
requested transaction. When we transfer or disclose your personal information to
other countries, we will protect that information as described in this Privacy
Statement. By submitting personal information via our website or other means,
you agree to such storage, transfers, and processing.


8. DATA SECURITY

We maintain reasonable physical, administrative, and technical safeguards to
protect your personal information. Our employees and third-party service
providers have access to your personal information only on a "need to know"
basis. We conduct regular internal audits of our business practices and
procedures in order to protect your personal information.

We take measures to delete your personal information or keep it in a form that
does not permit identifying you when this information is no longer necessary for
the purposes for which we process it, unless we are required by law to keep this
information for a longer period, as described in our records management policy.

In addition to our security measures, you can also take steps to enhance your
security online and to protect your confidential information. Additional
information on these topics can be found on our website at the Security Center.


9. LINKS TO OTHER SITES

Our websites or mobile applications may contain links or otherwise provide
access to another website, mobile application, or Internet location
(collectively “Third-Party Sites”). We have no control over and are not
responsible for Third-Party Sites, their content or any goods or services
available through the Third-Party Sites. This Statement does not apply to
Third-Party Sites. We encourage you to read the privacy policies of any
Third-Party Site with which you choose to interact.


10. NOTICE TO CALIFORNIA RESIDENTS

This section describes your rights under the California Consumer Privacy Act
(“CCPA”) and how to exercise those rights. Your CCPA rights are in addition to
the rights described in Section 5.

 

10.1 DESCRIPTION OF YOUR RIGHTS

Subject to certain exceptions and limitations, you have the following rights
with respect to covered personal information.

 * Right to request access to personal information. You have the right to
   request the following information from us.
   * Specific pieces of personal information we have about you;
   * Categories of personal information we have collected about you;
   * Categories of sources from which the personal information is collected;
   * Categories of personal information sold or disclosed, if any;
   * Categories of third parties with whom the personal information was sold or
     disclosed; and
   * The purpose(s) for collecting or selling the personal information.
 * Right to delete personal information: You have the right to request that we
   delete the personal information we have collected about you.
 * Right to opt-out of the sale of personal information: You have the right to
   request to be opted out from the sale of your personal information; however,
   as set forth in Section 3, we do not and will not sell personal information
   to third parties.
 * Right to Data Portability: In certain circumstances, you may have the right
   to receive personal information concerning you in a portable format.
   
 * Right not to be discriminated against for exercising the rights identified
   above: You have the right not to be denied goods or services, charged
   different prices or rates for goods or services, or receive a differing level
   of quality of goods or services as a result of exercising the above rights.

 

10.2 COVERED PERSONAL INFORMATION

The rights described in Section 10.1 do not apply to certain categories of
personal information. The personal information excluded from coverage under the
CCPA includes, among other things:

 * Personal information we collect from or about you when you apply for or
   obtain a product or service for personal, family or household purposes;
 * Personal information about communications or transactions with you when you
   are acting on behalf of a company or government agency to do business with
   us; and
 * Personal information sold or bought from a consumer reporting agency for use
   in a consumer report in compliance with applicable law.

We will apply verifiable consumer requests to covered personal information.

 

10.3 HOW TO SUBMIT A REQUEST

You or your authorized agent may submit a CCPA request using one of the
following methods:

 * Call 800-ETRADE-1 (800-387-2331) or
 * Access our CCPA request website

We will respond to authorized requests as soon as practicable and as required by
law. The above rights are subject to our ability to reasonably verify your
identity and authority to make these requests. In order to verify that you are
authorized to submit a request, you may be required to provide the following
information.

 * Customers: If you are a customer, you may verify your identity through
   account login.
 * Non-Customers: If you are not a customer, you may verify your identity by
   submitting certain non-sensitive identifiers. To help protect the security of
   your personal information, we may use a third-party service provider to
   verify your information, which may include receiving a one-time password via
   text message. By submitting your mobile phone number for identity
   verification, you consent to receiving text messages for this purpose.
 * Authorized Agents: If you are an authorized agent, you may verify your own
   identity by submitting certain non-sensitive identifiers. To help protect the
   security of your personal information and the personal information you are
   requesting, we may use a third-party service provider to verify your
   information, which may include receiving a one-time password via text
   message. By submitting your mobile phone number for identity verification,
   you consent to receiving text messages for this purpose. As an authorized
   agent, you also may be required to submit a legally sufficient Power of
   Attorney appointing you to act on behalf of the owner of the personal
   information a similar document deemed sufficient by E*TRADE to establish your
   authority.

Your CCPA rights are subject to various exclusions and exceptions under the law.
Under certain circumstances, we may be unable to implement your request,
pursuant to applicable law. We will advise you of any reason for denying or
restricting a request to the extent permitted by law.

We will not provide social security numbers, driver’s license numbers or
government issued identification numbers, financial account numbers, health
insurance or medical identification numbers, account passwords or security
questions and answers, or other specific pieces of personal information if the
disclosure presents an unreasonable risk to the security of personal
information, customer accounts or our systems and network security.


11. NOTICE TO NEVADA RESIDENTS

We are providing you with this notice pursuant to state law. You may be placed
on our internal Do Not Call list by calling us at 800-ETRADE-1 (800-387-2331).
For further information, contact the Nevada Attorney General’s office at 555 E.
Washington Ave., Suite 3900, Las Vegas, NV 89101; by phone at 702-486-3132; or
by email at BCPINFO@ag.state.nv.us.


12. NOTICE TO BRAZIL RESIDENTS

This section describes your rights under Lei Geral de Proteção de Dados (“LGPD”)
and how to exercise those rights.  Your LGPD rights are in addition to the
rights described in Section 5.

 

12.1 DESCRIPTION OF YOUR RIGHTS

Subject to certain exceptions and limitations, you have the following rights
with respect to your personal data, as defined by LGPD, processed by E*TRADE:

 * Confirmation of the existence of processing;
 * Access to your personal data;
 * Correction of incomplete, inaccurate or out-of-date personal data;
 * Anonymization, redaction or deletion of unnecessary or excessive personal
   data, or of personal data that is not being processed in compliance with the
   LGPD;
 * Portability of your personal data;
 * Deletion of personal data being processed based upon your consent;
 * Information about subprocessors and other third parties with whom personal
   data is shared;
 * Information about your consent choices and the consequences of denying
   consent;
 * Revocation of your consent;
 * Right to oppose any data processing activity for which your consent was not
   required if there is a breach of LGPD; and
 * Right to lodge a complaint with the Brazilian Data Protection Authority
   (“ANPD”).

 

12.2 HOW TO SUBMIT A REQUEST

You or your authorized agent may submit an LGPD request by contacting us using
the information in the “Contact Us” section of this Statement.

We will respond to authorized requests as soon as practicable and as required by
law at no cost to you.  The above rights are subject to our ability to
reasonably verify your identity and authority to make these requests.  In order
to verify that you are authorized to submit a request, you may be required to
provide the following information:

 * Customers.  If you are a customer, you may verify your identity through
   account login or by submitting certain non-sensitive identifiers.
 * Authorized Agents.  If you are an authorized agent, you may verify your own
   identity by submitting certain non-sensitive identifiers.  To help protect
   the security of your personal data and the personal data you are requesting,
   we may use a third-party service provider to verify your information, which
   may include receiving a one-time password via text message.  By submitting
   your mobile phone number for identity verification, you consent to receiving
   text messages for this purpose.  As an authorized agent, you also may be
   required to submit a legally sufficient Power of Attorney appointing you to
   act on behalf of the owner of the personal data or a similar document deemed
   sufficient by E*TRADE to establish your authority.

Your LGPD rights are subject to various exclusions and exceptions under the
law.  Under certain circumstances, we may be unable to implement your request,
pursuant to applicable law.  We will advise you of any reason for denying or
restricting a request to the extent permitted by law


13. ACCESSIBILITY

To obtain a copy of this Statement in Braille or in large print, please call our
accessibility technical support line at 866-284-2145 or email us at
techsupport@etrade.com.


14. UPDATES TO THIS STATEMENT

We may update this Statement from time to time. We encourage you to periodically
review this Statement to learn about updates to our privacy practices.


15. CONTACT US

For more information about our privacy practices, or if you have questions or
concerns, please visit the Contact Us page on our website or call
800-387-2331 (from within the U.S.) or 001-800-387-2331 (from outside the
U.S.).  You may also email us at cpo@etrade.com or contact us by mail at the
following address:

E*TRADE
P.O. Box 484
Jersey City, NJ 07303-0484


ETRADE FOOTER



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E*TRADE SECURITIES LLC AND E*TRADE CAPITAL MANAGEMENT, LLC RELATIONSHIP SUMMARY.

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