Institutional: Discloses the way we collect, protect, and use the personal information of our advisor clients and their choices with respect to third-party sharing.

Vermont Residents: In accordance with Vermont law, we will not share information we collect about Vermont residents with companies that are not affiliates, except as permitted by law, such as with your consent or to service your accounts. We will not share information about your creditworthiness with our affiliates without your authorization or consent, but we may share information about our transactions or experiences with you with our affiliates without your consent.

Sweepstakes: Covers our potential collection and use of information provided as part of a sweepstakes, contest, or giveaway, including notifying participants that the actual rules of any particular sweepstakes will control that sweepstakes.

Third-party service: Covers our use of first- and third-party cookies on our pages and advertisements and how you can opt out of the collection. TD Ameritrade gives everyone the choice of controlling and deleting cookies from visits to our sites.

We collect information from you when you visit our website, register on our site, place an order, subscribe to our newsletter, respond to a survey or fill out a form.

• Name / Username
• Phone Numbers
• Email Addresses
• Password

We keep your information only so long as we need it to provide SmartShares to you and fulfill the purposes described in this policy.

This is also the case for anyone that we share your information with and who carries out services on our behalf. When we no longer need to use your information and there is no need for us to keep it to comply with our legal or regulatory obligations, we’ll either remove it from our systems or depersonalize it so that we can't identify you.

We implement a variety of security measures to maintain the safety of your personal information when you sign up on SmartShares or enter, submit, or access your personal information. We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential.

After a transaction, your private information (credit cards, social security numbers, financials, etc.) is never kept on file. We cannot, however, ensure or warrant the absolute security of any information you transmit to SmartShares or guarantee that your information on the Service may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, technical, or managerial safeguards.