Global Futures & Forex, Inc. (‘GFF Brokers”) is committed to safeguarding the personal information that you provide us. This Privacy Statement describes how we handle and protect personal information we collect about individuals, such as you, who apply for or receive our products and services. The provisions of this notice apply to former customers as well as our current customers.

Why and How We Collect Personal Information

When you apply for or maintain an account serviced by GFF Brokers, we collect personal information about you for business purposes, such as evaluating your financial needs, processing your requests and transactions, informing you about products and services that may be of interest to you, and providing customer service. The personal information we collect about you includes:

• information you provide to us on applications and other forms, such as your name, address, date of birth, social security number, occupation, assets, income, net worth, previous investment experience, and other confidential information considered necessary by us and your FCM to obtain in order to establish an account;

• information about your transactions with us;

• information we may receive from reporting agencies, such as your credit history and creditworthiness, background information, and other entities not affiliated with GFF Brokers;

• recorded conversations between yourself and an associated person of GFF Brokers; and,

• information you provide to us to verify your identity, such as a passport, or information received from other entities not affiliated with GFF Brokers.

How We Protect Personal Information

We limit access to your personal information to those employees who need to know in order to conduct our business, service your account, and help you accomplish your financial objectives, such as providing you with a range of products and services. Our employees are required to maintain and protect the confidentiality of your personal information and our employees are instructed as to best practice methodologies for processing and maintaining confidential customer information.

We maintain physical, electronic, and procedural safeguards to protect your personal information.

We do not rent or sell your company information, your name or personal information to anyone. However, GFF Brokers reserves the right to disclose personal information when it is necessary to fulfill GFF Brokers’ regulatory requirements, protect GFF Brokers’ intellectual or physical property, collect or report debts owed to GFF Brokers, or exercise any right of law on behalf of GFF Brokers.

Disclosure to Non-Affiliated Third Parties

In order to support the financial products and services we provide to you, we may share the personal information described above with third-parties not affiliated with us, including:

• Companies under contract to perform services for us or on our behalf, such as vendors that provide data processing, computer software maintenance and development, transaction processing and marketing services.

• Compliance, accounting, and legal firms that assist GFF Brokers in complying with regulatory requirements. These companies acting on our behalf have been requested by GFF Brokers to keep your personal information confidential. GFF Brokers obtains assurance that the companies maintain privacy statements of their own, however, GFF Brokers is not responsible for the privacy policies of these entities.

• Companies and regulatory authorities as permitted or required by applicable law. For example, we may disclose personal information to cooperate with regulatory authorities and law enforcement agencies to comply with subpoenas or other official requests, and as necessary to protect our rights or property.

Conversations with GFF Brokers Representatives

As of December 21, 2013, the Commodity Futures Trading Commission Regulation 1.35 (a) began requiring firms like GFF Brokers to keep a record of (and therefore tape record) all oral communications provided or received concerning quotes, solicitations, bids, offers, instructions, trading and prices that lead to the execution of a transaction in a commodity interest and related cash or forward transaction, whether communicated by telephone, voicemail, mobile device, or other digital or electronic media, for a period of one year. GFF Brokers must record such communications regardless of whether it occurred on a firm provided or personal phone. It is GFF Brokers Policy that no representative is permitted to speak to a customer concerning quotes, solicitations, bids, offers, instructions, trading and prices that lead to the execution of a transaction in a commodity interest and related cash or forward transaction unless the conversation is done over a device that is recorded using technology provided and maintained by GFF Brokers.

Customers and FDMs must consent to the recording of all oral communications that are subject to recording Rules. The receipt of this Privacy Policy is your notice that all conversation between you and a registered associated person of GFF Brokers will be recorded and maintained on file under secure measures as outlined in this notice for a period of one year. Should you object to this recording policy, you will need to notify our office within 10 calendar days of your refusal to being recorded while speaking with a registered associated person of GFF Brokers.  After this 10 calendar day period, your silence will be accepted as your consent to this policy.

Except as described in this privacy policy, we will not use your personal information for any other purpose unless we describe how such information will be used at the time you disclose it to us or we obtain your permission to do so.

We consider your privacy a very important matter and appreciate the information you have entrusted to us.


Greg Khojikian, President