Commune Capital, LLC. (hereinafter “Commune”) strongly believes in protecting the
confidentiality and security of information we collect about individuals. This notice describes the
• How we treat the information we receive (“Information”) about individuals who apply for or
obtain our products or services (“Individuals”); and
• Any third parties with whom we may share this Information with.
INFORMATION WE COLLECT
“Nonpublic Personal Information” is nonpublic information about the Individual that we obtain in
connection with providing a financial product or service to the Individual for personal, family, or
We collect Nonpublic Personal Information about Individuals from the following sources:
• Information provided to us directly by an Individual on an application or other form in
connection with our products or services. This may include but not be limited to: name,
address, social security number, assets, and income.
• Information about an Individual’s transactions with us, our affiliates, or others, such as
account balance, payment history, parties to a transaction, and insurance information.
• Information you provide to us and related identity documents are being requested to verify
your identity in accordance with Section 326 of the USA Patriot Act.
INFORMATION DISCLOSED TO THIRD PARTIES, SERVICE PROVIDERS AND JOINT
We do not disclose any Nonpublic Personal Information about our customers or former
customers to third parties, except upon permission from such Individual or upon direction of a
court of law or other government authority, or to our service providers as outlined below.
Nonpublic Personal Information may be disclosed as necessary to service provider institutions.
Such institutions presently include financial service institutions such as custodians and broker-
dealers through whom customers’ transactions are executed, and technology service providers
such as our database programmers. All service providers must limit their use of information to
the purpose for which it was provided.
We do not currently have joint marketing partners to whom we disclose any Nonpublic Personal
Information. In the event that we decide to engage in such a relationship, we will obtain
permission from customers or former customers to disclose any Nonpublic Personal
Information. Furthermore, these institutions will be prohibited by agreement from using such
Nonpublic Personal Information except for the narrow purpose for which it was given to them.
PROTECTING CONFIDENTIALITY AND SECURITY
We treat Information in a confidential manner. Our employees are required to protect the
confidentiality of Information. Employees may access Information only when there is an appropriate reason to do so, such as to administer or offer our products and services.
Employees are subject to disciplinary rules if they do not comply with our policies. We also
maintain physical, electronic, and procedural safeguards to protect Information; these
safeguards comply with all applicable laws.
DISCLOSURE OF INFORMATION ABOUT FORMER CUSTOMERS
If an Individual decides to close an account or otherwise becomes an inactive customer, we will
continue to follow the privacy practices described in this notice with respect to such Individual.