BRITEHORN SECURITIES PRIVACY POLICY

Britehorn Securities, LLC (“Britehorn” or the “Firm”) recognizes and embraces the importance of keeping our customers’ confidential financial information private. Federal legislation requires us to notify our customers of our privacy practices by describing the types of non-public information we may collect in the ordinary course of business, and explain the ways that we protect their privacy:

  • We will safeguard, according to strict standards of security and confidentiality, nonpublic, personal information our customers share with us. “Nonpublic, personal information,” for example, would include such information as your home address, social security number and credit information. We will maintain safeguards to protect that information and conduct our business in a manner that keeps personal customer information secure.
  • We will limit the collection and use of customer information to the minimum we require to deliver exceptional service and to administer our business, recognizing, however, that we may need to obtain confidential information to provide financial advisory work and to conduct appropriate due diligence in our investment banking business.

We collect personal information from customers from the following sources:

  • From customers on engagement letters, related agreements, and in the course of our examination of your business and prospects;
  • From your transactions with us, our affiliates and others;
  • From non-affiliated third parties in the course of our due diligence. We restrict access to non-public personal information to Britehorn’s employees and agents who need to know this information to provide products or services to you.

It is Britehorn’s policy that we will not share personal customer information (of either current or former customers) outside of Britehorn for any purpose other than the providing of investment banking services or the brokering or underwriting of securities transactions on behalf of the customer, unless the disclosure has been authorized by the customer or is permitted by law. Whenever we retain other organizations to provide support services on behalf of Britehorn we will require them to protect customers’ personal information.

When necessary, we will review and revise our Privacy Policy to protect personal customer information.

BRITEHORN SECURITIES BUSINESS CONTINUITY PLAN

BUSINESS CONTINUITY PLANNING DISCLOSURE STATEMENT Britehorn Securities, LLC (“Britehorn” or the “Firm”) is committed to safeguarding the interests of our subscribers in the event of an emergency or significant business disruption.

This Business Continuity Plan (the “BCP”) Disclosure summarizes the Firm’s efforts to mitigate risks inherent with unforeseen business interruptions. The Firm’s comprehensive business continuity strategy is designed to enable us to meet our existing obligations to our subscribers even in the event of an emergency or significant business disruption.

This BCP is intended to comply with the rules promulgated by the Financial Industry Regulatory Authority (“FINRA”). The Firm’s policy is to respond to significant business disruptions by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the Firm’s books and records, and ensuring that our clients can continue to transact business.

Examples of potential scenarios that might cause some changes to our regular business operations:

  • In the event of a significant business disruption of any type that affects our primary office in Colorado, we will transfer our business operations to one or more remote sites in the United States;
  • We do not anticipate that power outages at our primary office will require us to shut down our business. No contingency plan can eliminate all risk of service interruption or temporarily impaired access to the Firm.

We will evaluate and revise our BCP to address risks to the extent possible. In developing our BCP, we have made certain assumptions regarding accessibility and availability of alternative facilities, the ability of a sufficient number of our personnel to man our systems, and external organizations including securities markets and government agencies being operational. If these assumptions are not valid under particular circumstances, we will evaluate possibilities for minimizing the disruption to services as feasible at that time.

We will update the BCP as needed in the event of changes to our business processes, technology and staff. We will continue to post updated information on our website. Users may also obtain our current BCP summary by submitting a written request to:

 

Britehorn Securities LLC

ATTN: Business Continuity Plan

1888 Sherman Street, Suite 770

Denver CO 80203.

 

The Firm’s business continuity strategy is designed to enable us to meet our existing obligations to our clients even in the event of an emergency or significant business disruption; however it is not without limits. The BCP is designed to work diffferent emergency situations, but these events are, by their nature, unpredictable and it is impossible to anticipate every scenario that could cause a business disruption.

Although we are confident in our own preparedness, Britehorn has no control over the various entities that we must rely upon in the event of an emergency. Our BCP is tested periodically to ensure readiness. However, such tests may not be able to replicate the actual conditions we experience in a real emergency.

This BCP disclosure statement is subject to change without notice. In the event that the BCP or the BCP disclosure statement is modified, the updated document will be promptly posted on the Britehorn website (www.Britehornsecurities.com). Alternatively, clients of the Firm may obtain an updated hard copy of the BCP disclosure statement upon request. The information contained in this BCP disclosure statement is provided by Britehorn for informational purposes only. Nothing contained herein shall be construed to amend, supplement or otherwise modify any of the terms and conditions set forth in any client agreement between you and Britehorn.