Privacy Policy and Investor Privacy Notice

Last Updated: August 7, 2026

First Liberties Securities, Inc. d/b/a First Liberties Financial (“First Liberties,” “FLF,” “we,” “us,” or “our”) respects the privacy of our customers, prospective customers, website visitors, and other individuals who interact with us.

This Privacy Policy and Investor Privacy Notice describes how we collect, use, disclose, and protect personal information, including nonpublic personal information obtained in connection with brokerage and other financial services.

First Liberties is a registered broker-dealer and member of the Financial Industry Regulatory Authority (“FINRA”), the Securities Investor Protection Corporation (“SIPC”), and the Municipal Securities Rulemaking Board (“MSRB”).

Our privacy practices are governed by applicable federal and state law, including, where applicable, the Gramm-Leach-Bliley Act and Regulation S-P.

1. Information We Collect

The information we collect depends on your relationship and interactions with First Liberties.

We may collect information directly from you, through transactions and accounts, from service providers and other financial institutions, from regulatory or governmental sources, from consumer reporting agencies where permitted, and through our website.

Information You Provide to Us

We may collect information you provide in connection with a brokerage account, securities transaction, investment banking engagement, inquiry, or other financial product or service, including:

  • name;
  • address;
  • email address;
  • telephone number;
  • Social Security number, taxpayer identification number, or other identifying information;
  • date of birth;
  • employment and occupation information;
  • financial information, including income, assets, liabilities, net worth, investment holdings, and liquidity;
  • investment objectives, risk tolerance, and investment experience;
  • account and transaction information;
  • tax-related information;
  • identification documents;
  • information contained in agreements, account applications, subscription documents, questionnaires, and other forms; and
  • other information you choose to provide to us.

Information About Your Transactions and Accounts

We may collect information concerning your relationship and transactions with First Liberties and other financial institutions, including:

  • account balances;
  • securities holdings;
  • purchases and sales of securities;
  • transaction history;
  • payment and settlement information;
  • account activity;
  • communications relating to transactions; and
  • other information necessary to service an account or complete a transaction.

Information From Other Sources

We may obtain information from other sources where permitted by law, including:

  • clearing firms and custodians;
  • financial institutions;
  • issuers and transfer agents;
  • investment advisers and other financial professionals;
  • consumer reporting agencies;
  • identity verification and anti-money laundering service providers;
  • regulatory and governmental agencies;
  • public records and publicly available sources; and
  • other parties involved in a financial transaction or business relationship.

2. Information Collected Through Our Website

When you visit www.firstlibertiesfinancial.com or otherwise interact with our Website, we may collect information that you voluntarily provide to us.

For example, if you contact us through a website form or email link, we may receive your:

  • name;
  • email address;
  • telephone number;
  • company or organization;
  • message or inquiry; and
  • other information you choose to provide.

Our Website and the service providers that support it may also automatically collect certain technical information, such as:

  • Internet Protocol (IP) address;
  • browser type;
  • device type;
  • operating system;
  • pages visited;
  • referring website;
  • date and time of access; and
  • similar technical and usage information.

Cookies and similar technologies may be used where enabled to support website functionality, security, analytics, or performance.

You may be able to limit certain cookies through your browser settings. Disabling cookies may affect the operation of certain website features.

3. How We Use Information

We may use personal information and nonpublic personal information for purposes including:

  • establishing and servicing brokerage accounts and other relationships;
  • processing securities transactions;
  • communicating with customers, prospective customers, issuers, investors, and other parties;
  • responding to inquiries;
  • providing products and services requested by you;
  • determining eligibility or suitability for particular products or transactions where applicable;
  • performing customer identification, anti-money laundering, sanctions, and other regulatory checks;
  • maintaining required books and records;
  • complying with legal, regulatory, tax, reporting, and supervisory obligations;
  • preventing and detecting fraud, cybersecurity threats, or unauthorized activity;
  • protecting our rights, systems, personnel, customers, and property;
  • administering and improving our Website;
  • conducting internal business operations;
  • managing relationships with service providers; and
  • other purposes permitted or required by law.

4. Our Policy Regarding the Sale of Personal Information

First Liberties does not sell your nonpublic personal information.

We do not disclose nonpublic personal information to nonaffiliated third parties for their independent marketing purposes except where permitted by applicable law or where you have provided appropriate authorization.

We may disclose information as necessary to provide financial products or services, conduct our business, comply with regulatory obligations, protect against fraud or security threats, or as otherwise permitted or required by law.

5. Information We May Disclose

We may disclose personal information or nonpublic personal information to the following categories of parties where appropriate and permitted by law.

Financial Institutions and Transaction Participants

Information may be disclosed to parties involved in providing or facilitating financial products and services, including:

  • clearing firms;
  • custodians;
  • banks and other financial institutions;
  • issuers;
  • transfer agents;
  • broker-dealers;
  • investment advisers;
  • fund administrators;
  • attorneys, accountants, and other transaction professionals; and
  • other parties necessary to complete, settle, administer, or service a transaction or account.

Service Providers

We may provide information to third-party service providers that perform services on our behalf, such as:

  • technology and information technology providers;
  • cybersecurity providers;
  • recordkeeping and archival providers;
  • communications providers;
  • identity verification and compliance providers;
  • accounting and professional service providers;
  • website hosting and infrastructure providers; and
  • other vendors supporting our operations.

Where required by applicable law, such service providers are subject to contractual or other requirements governing their use and protection of customer information.

Affiliates

First Liberties may share information with affiliated entities, including Pelion Investment Advisors, Inc., where permitted by applicable law and appropriate in connection with products, services, administration, compliance, or other legitimate business purposes.

Any sharing of information among affiliated entities remains subject to applicable privacy, securities, and consumer-protection laws and any rights or notices required under those laws.

Legal and Regulatory Purposes

We may disclose information:

  • to FINRA, the SEC, the MSRB, state securities regulators, law enforcement agencies, courts, or other governmental or regulatory authorities;
  • in response to subpoenas, court orders, regulatory requests, examinations, investigations, or other legal process;
  • to comply with applicable laws, rules, and regulations;
  • to prevent fraud, money laundering, cybersecurity incidents, or other unlawful activity;
  • to enforce or protect our legal rights; or
  • where otherwise permitted or required by law.

6. Former Customers

If your customer or other relationship with First Liberties ends, we may continue to retain and protect your information in accordance with this Privacy Policy, applicable law, regulatory recordkeeping requirements, and our information-retention policies.

We do not treat nonpublic personal information concerning former customers as freely available merely because the customer relationship has ended.

7. Protecting Your Information

First Liberties maintains administrative, technical, and physical safeguards designed to protect customer information from unauthorized access, use, modification, disclosure, loss, or destruction.

Our information-security practices are designed to address the nature and sensitivity of the information we maintain and applicable legal and regulatory requirements.

These safeguards may include access controls, authentication procedures, information-security controls, physical protections, employee procedures, vendor oversight, incident-response procedures, and other measures appropriate to our operations.

No method of electronic transmission or storage can be guaranteed to be completely secure. Accordingly, while we take appropriate measures to protect information, we cannot guarantee absolute security.

8. Security Incidents

First Liberties maintains policies and procedures designed to respond to unauthorized access to or use of customer information.

Where required by applicable law, First Liberties will provide notification regarding security incidents involving sensitive customer information within the time and manner required by applicable law and regulation.

The SEC's amended Regulation S-P requires covered broker-dealers to maintain written incident-response procedures addressing unauthorized access to or use of customer information and, subject to specified exceptions, to notify affected individuals of qualifying incidents.

9. Electronic Communications

Email, general website contact forms, and other ordinary electronic communications may not be secure.

You should not send passwords, Social Security numbers, account credentials, payment credentials, or other highly sensitive information through the Website's general contact form or through ordinary email unless specifically instructed to do so through an appropriate secure method.

First Liberties does not accept securities orders, fund-transfer instructions, or other time-sensitive brokerage instructions through the Website's general contact form.

10. Third-Party Websites

Our Website may contain links to websites or services maintained by third parties.

First Liberties does not control the privacy, security, or information-handling practices of third-party websites. This Privacy Policy does not apply to information collected independently by those third parties.

You should review the privacy policies of third-party websites before providing personal information through them.

11. Data Retention

First Liberties retains information for periods reasonably necessary to provide services, conduct business operations, satisfy legal and regulatory obligations, resolve disputes, protect our rights, and comply with applicable books-and-records requirements.

Retention periods may vary depending on the type of information, the nature of the relationship, and applicable legal or regulatory requirements.

12. Children's Privacy

The Website is not directed to children under the age of 13, and First Liberties does not knowingly use the Website to solicit personal information from children under 13.

If we become aware that personal information has been collected from a child in circumstances prohibited by applicable law, we will take appropriate steps to address the information.

13. Your Privacy Rights

Depending on your relationship with First Liberties and applicable federal or state law, you may have certain rights regarding your personal information.

Certain financial information maintained by First Liberties is governed primarily by federal financial privacy and securities laws, including the Gramm-Leach-Bliley Act and Regulation S-P.

Where applicable law provides additional rights, First Liberties will respond to requests in accordance with those requirements.

Nothing in this Privacy Policy is intended to limit any privacy rights provided by applicable law.

14. Regulation S-P and Customer Privacy Notices

Regulation S-P requires broker-dealers to provide customers with notices that accurately describe the firm's policies and practices regarding the collection and disclosure of nonpublic personal information. Required disclosures depend in part on the categories of information collected, the parties to whom information is disclosed, and whether disclosures are made pursuant to regulatory exceptions.

First Liberties may provide customers with additional privacy notices at the time a customer relationship is established and at other times when required by applicable law.

This Website Privacy Policy does not replace any separate privacy notice, disclosure, agreement, or communication that First Liberties is required to deliver directly to a customer.

If a separate customer privacy notice applies to your relationship with First Liberties, that notice should be read together with this Privacy Policy.

15. Changes to This Privacy Policy

First Liberties may update this Privacy Policy periodically to reflect changes in our practices, technology, services, legal requirements, or regulatory requirements.

When this Privacy Policy is revised, the “Last Updated” date at the top of the page will be updated.

If applicable law requires additional notice regarding a material change in our privacy practices, we will provide such notice as required.

16. Contact Us

Questions regarding this Privacy Policy or First Liberties' privacy practices may be directed to:

First Liberties Securities, Inc. d/b/a First Liberties Financial
2915 N. Boulevard, Suite A
Tampa, Florida 33602

Telephone: (917) 639-5451
Email: compliance@firstlibertiesfinancial.com

First Liberties Securities, Inc. d/b/a First Liberties Financial is a registered broker-dealer and member of FINRA, SIPC, and MSRB.

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