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Cheevers Website Disclaimer (Legal) LEGAL DISCLAIMER. All the information on this website is provided for informational purposes only without regard to any particular user's investment objectives, financial situation, or means, and by posting such information Cheevers & Company, Inc. (“Cheevers”) is not soliciting any action based upon such information. The information provided is not to be construed as a recommendation; or an offer to buy or sell; or the solicitation of an offer to buy or sell any security, financial product, or instrument; or to participate in any particular trading strategy in any jurisdiction in which an offer, solicitation, purchase or sale would be unlawful under the securities laws of such jurisdiction. No investment advice, tax advice, or legal advice is provided through this website, and you agree that this website will not be used by you for these purposes. No representation is given that the securities, products, or services discussed herein or accessible through this website are suitable for any particular investor. You acknowledge that your use of this website and requests for information are unsolicited, and the provision of any information through this website shall not constitute or be considered investment advice. The contents of this site are not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to local law or regulation. Cheevers makes no representation that the contents of this site are appropriate for use in all locations, or that the transactions, securities, products, instruments or services discussed at this site are available or appropriate for sale or use in all jurisdictions or countries, or by all investors or counterparties. GENERAL USE RESTRICTIONS. All information, documents, products, software, services and other materials (the "Materials") provided on this Site are the property and copyrighted work of Cheevers or a third party developer, author, manufacturer or vendor (the "Third Party Provider"). Except as stated in these legal terms, none of the Materials may be copied, downloaded, reproduced, distributed, republished, displayed, posted or transmitted in any form or by any means, including but not limited to electronic, mechanical, photocopying or recording, without the prior express written permission of Cheevers or the Third Party Provider. No part of this Site, including but not limited to any logo, graphic, sound or image, may be reproduced or retransmitted in any way, or by any means, without the prior express written permission of Cheevers. You also may not, without Cheevers prior express written permission, "mirror" any Material on any other server. Any unauthorized use of any Information or Materials displayed herein may violate copyright laws, trademark laws, the laws of privacy and publicity, and communications regulations and statutes. LIMITATION OF LIABILITY. IN NO EVENT WILL CHEEVERS, ITS SUPPLIERS, OR THIRD PARTIES MENTIONED AT THIS SITE BE LIABLE FOR ANY DAMAGES WHATSOEVER (INCLUDING, WITHOUT LIMITATION, THOSE RESULTING FROM LOST PROFITS, LOST DATA OR BUSINESS INTERRUPTION) ARISING OUT OF THE USE, INABILITY TO USE, OR THE RESULTS OF USE OF THIS SITE, ANY WEB SITES LINKED TO THIS SITE, OR THE MATERIALS OR INFORMATION CONTAINED AT ANY OR ALL SUCH SITES, WHETHER BASED ON WARRANTY, CONTRACT, TORT OR ANY OTHER LEGAL THEORY AND WHETHER OR NOT ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. BECAUSE SOME JURISDICTIONS PROHIBIT THE EXCLUSION OR LIMITATION OF LIABILITY FOR CONSEQUENTIAL OR INCIDENTAL DAMAGES, THE ABOVE LIMITATION MAY NOT APPLY TO YOU. DISCLAIMER. ALL MATERIALS AND INFORMATION ARE PROVIDED "AS IS" AND WITHOUT ANY WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE OR NON-INFRINGEMENT OF INTELLECTUAL PROPERTY. Further, Cheevers does not warrant the accuracy or completeness of any of the Materials. Cheevers may change any of the Materials at any time without notice. The Materials may be out of date, and Cheevers makes no commitment to update the Materials. Privacy Policy and Security disclaimer Commitment to Privacy. Cheevers & Company, Inc. (“Cheevers”) is committed to maintaining your confidence and trust, and accordingly maintains the following Privacy Policy to protect the personal information you provide online. Questions regarding this policy should be directed to the Chief Compliance Officer, Ryan Peterson at This e-mail address is being protected from spambots. You need JavaScript enabled to view it or (312) 663-2799. Collection and Use of Information. Cheevers will not collect any personal information about you (such as your name, address, or telephone number) unless you provide it voluntarily. If you do not want this information to be collected by us, please do not submit it. In the course of using our site, however, we may automatically track certain information about you. This information could include the URL that you just came from (whether this URL is on our site or not), which URL you go to next (whether this URL is on our site or not), what browser you are using, and your IP address. In addition, we may use cookies on certain pages of our site. Cookies are small amounts of data that are sent to your browser from our web server and are stored on your computer's hard drive, not on our site. Cookies allow us to track where you go on our site, or to make it easier for you to return on subsequent visits to those area that are of most interest you. Cookies can also help us provide information that is targeted to your interests. You are always free to decline our cookies if your browser permits, however, removing cookies may reduce the speed at which you move through our site. We will only use the information provided through our site to help us improve our services to you, to provide you with the products you have requested, to inform you about additional products or services that may be of interest to you, for marketing purposes and for other internal purposes. Cheevers does not sell, trade, or rent your personal information to outside advertising agencies, promotional agencies, consultants, or other outside entities. Consent. By using our Web site, you consent to the collection and use of this information by Cheevers. Cheevers may modify this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post those changes on this page. Your continued use of this site following the posting of changes to these terms will mean you accept these changes. Security. Cheevers employs physical, electronic, and managerial procedures to reasonably safeguard the security and integrity of client information. Billing and payment data is encrypted whenever transmitted or received online. Client information is accessible only by staff designated to handle online requests or complaints. All Cheevers agents and contractors with access to client information on the Cheevers web site(s) are bound to adhere to Cheevers policies and procedures governing security standards. In attempting to achieve information security and quality, Cheevers implements reasonable measures and processes, such as using encryption when transmitting certain sensitive information. Cheevers will exercise all reasonable efforts to safeguard the confidentiality of client information. However, transmissions protected by industry standard security technology and implemented by human beings cannot be made absolutely secure. Consequently, Cheevers shall not be liable for unauthorized disclosure of client information due to no fault of Cheevers including, but not limited to, errors in transmission and unauthorized acts of Cheevers staff and/or third parties. Direct Market Access (DMA) Disclaimer Prior to offering a client Direct Market Access functionality Cheevers & Company (“Cheevers”) will conduct appropriate due diligence to determine limits based on a clients business, financial condition, trading patterns, and other information. Cheevers will require information regarding what type of trading the client will place via this system and expected order sizes. Due to these circumstances, this functionality may not be available to every client. Cheevers may, at our discretion, refuse to process any transaction, or process any transaction until reviewed and accepted. All clients who have direct access to algorithms via this functionality have their orders flow directly through Cheevers systems where they can be monitored, modified, or possibly cancelled (if appropriate). Additionally, Cheevers has implemented pre-trade limits (e.g. price, shares, and total value) to ensure that a client does not enter an order that would jeopardize Cheevers or a client’s liquidity or be executed in a manner inconsistent with applicable rules and regulations. It is also important to note that the executing broker to which the algorithm is routed, if applicable, has certain order controls in place which could limit a clients trading. Regarding Direct Market Access functionality, to any Exchange to which a client may submit orders or receive information or data using our systems, each client grants Cheevers the right, at any time, on reasonable notice (which, in certain circumstances, may be immediate) to revoke client use of DMA functionality if client trading is not meeting the requirements of any relevant Exchange or Applicable Regulations. Each client is required to test any interface (e.g. FIX) prior to using it in a live environment and each client agrees to accept responsibility for any errors or failure in their implementation of the interface protocol. Cheevers does not offer “sponsored access” to its customers (defined as when a “customer’s orders flow directly into the markets without first passing through the broker-dealers systems.” SEC Release 34-61379 p.6). Cheevers does not allow any client to utilize our MPID in order to access, or report trades, on any exchange. Anti-Money Laundering Notice to Clients In order to meet our Regulatory and Business requirements relating to Anti-Money Laundering, terrorism, organized crime activities and Know Your Customer rules, Cheevers & Co., Inc. (“Cheevers”), member CHX/FINRA/SIPC, requires that all clients complete a Client Information Form (“CIF”). This form provides Cheevers with the necessary identifying information for your firm and assists us in identifying each entity that opens an account/establishes a relationship with Cheevers for the provision of a product and/or service. As an industry participant, you may already be subject to, or familiar with, the regulations/obligations regarding Know Your Client (“KYC”), Anti-Money Laundering (“AML”) and Customer Identification Programs (“CIP”). Additional Information Important Information About Procedures for Opening a New Account To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person or entity that opens an account. What this means for you: When you open an account, we will ask for your name, business address, type of business and other information that will allow us to identify your firm. We may also ask to see your other identifying documents such as articles of incorporation. U.S. citizen: taxpayer identification number (Social Security number or employer identification number) Non-U.S. citizen: taxpayer identification number; passport number and country of issuance; alien identification card number; or government-issued identification showing nationality, residence and a photograph of you. A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, government-issued business license, a partnership agreement or a trust agreement. U.S. Department of the Treasury, Securities and Exchange Commission, FINRA and New York Stock Exchange rules already require you to provide most of this information. These rules also may require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience and objectives and risk tolerance. What happens if I don’t provide the information requested or my identity can’t be verified? Your account may not be opened or have the ability to carry out transactions. If the firm has already opened an account for you, they may have to close it. Please contact compliance if you have any further questions.