Commitment to Privacy

Your privacy is important to OTR. The firm recognizes and respects your wish for privacy and will continue to protect the information you share with OTR either in person, by telephone, by mail or via the Internet. The firm has always been committed to maintaining the confidentiality, integrity and security of personal information entrusted to us by current, prospective and former customers. This notice describes OTR's privacy policies and practices with respect to non-public personal information (the “Information”) and is designed to help you understand what Information OTR gathers, how the firm uses and protects that Information and the circumstances under which OTR may share that Information.

Collecting Customer Information

The primary reason that OTR collects and maintains Information about you is to open and service your account. The categories of Information that the firm collects are as follows:

  • Information received from you or your representatives on applications and other forms such as your name, address, telephone number, fax number, email address, social security number, birth date, bank reference, family information, financial information, financial goals and name, address and telephone number of your employer.
  • Information about your transactions and account experience with us, such as your holdings and trades.
  • Information OTR may receive from a consumer reporting agency.
  • OTR uses cookies in order to provide services and to improve the user experience. A cookie is a piece of information that a website stores on the web browser on your PC and can later retrieve. For example, through the use of cookies, Login can "remember" your user ID.

How OTR Protects Information

Within the Firm, OTR is careful to restrict access to Information to its employees based on their responsibilities and their need to know the Information to assist in servicing or managing your account(s) and responding to any inquiries from you regarding your account(s). OTR maintains safeguards in keeping with industry standards and practices and changes in technology to protect against anyone gaining unauthorized access to the Information.

OTR will not share Information with non-affiliated third parties without your specific consent or direction, except as described below. The firm may disclose Information to non-affiliated third party financial service providers such as its clearing agent. OTR is careful in selecting these firms, and requires them to maintain controls to protect the confidentiality and security of the Information. The firm does not permit them to use the Information for any reason other than providing the services necessary for the conduct of its business on your behalf. OTR do not sell client lists or any Information. Even if you are no longer an OTR client, the Privacy Statement will continue to apply to your Information.

OTR may also disclose Information to government and law enforcement agencies and officials for tax reporting or pursuant to subpoena, court order or other judicial process, to regulatory agencies for purposes of demonstrating compliance with the rules and regulations governing its business, to other organizations for fraud protection, to its attorneys, accountants and auditors for audit and other purposes and otherwise to comply with applicable federal, state and local laws, rules and requirements.

Maintaining Accurate Information

OTR strives to maintain complete and accurate Information about you and your account(s). If you ever believe that OTR's records contain inaccurate or incomplete Information, please let us know immediately. The firm will correct any inaccuracies as quickly as possible.

OTR reserves the right to change its Privacy Statement. The examples contained within this notice are illustrations and are not intended to be exclusive. This notice complies with Regulation S-P promulgated by the United States Securities and Exchange Commission. You may have additional rights under other laws.