MTS Securities, LLC – MTS Health Partners

623 Fifth Avenue, 14^th Floor, New York, New York 10022

PRIVACY POLICY NOTICE

MTS Securities, LLC respects your right to privacy and recognizes our responsibility for protecting the privacy and security of the personal information we receive from you. We have always been committed to securing the confidentiality and integrity of your personal information. We are proud of our privacy practices and want our current and prospective customers to understand what information we collect and how we use it. This notice refers to MTS Securities and its affiliated company, MTS Health Partners, and we refer to such companies collectively herein using the terms “we” or “our.”

Why We Collect Your Information

We gather and keep only information about you that is necessary for us to provide the services requested by you, administer your business with us, design and improve the services we offer and comply with the laws and regulations that govern us.

What Information We Collect

We may collect the following types of ‘non-public personal information’ about you:

• Personally Identifiable Information (PII).
• Information about your identity, such as your name, address, and social security number.
• Information about your transactions.
• Information about your personal financial profile, such as your risk tolerance levels, goals and objectives, assets, liabilities, savings, and investments.
• Non-Personally Identifiable Information (Non-PII).
• Browser type, device ID, and IP address.

How We Use Your Information

We may use your information to:

• Verify investor eligibility.
• Facilitate transactions and fulfill service requests.
• Respond to inquiries and customer service requests.
• Deliver communications and regulatory updates.
• Maintain regulatory records.
• Improve site experience and compliance.
• Provide good faith disclosures to regulators who have regulatory authority over us.

What Sources We Obtain Your Information From

We collect non-public personal information about our clients, such as you, from the following sources:

• Information we receive from you on contracts or other forms, such as risk tolerance questionnaires and/or investment policy statements.
• Information about your transactions with our affiliates, or others.
• If you visit our website, we collect information via a web server (often referred to as a “cookie”). Cookies indicate where a site visitor has been online and what has been viewed.

What Information We Disclose

We only share your non-public personal information with non-affiliated companies or individuals as permitted by law, such as your representative within our firm, affiliates, and other product vendors, or to comply with legal or regulatory requirements. With your approval, we may also share information with your advisors, which can include your accountant and/or attorney. Additionally, in the normal course of our business, we may disclose information we collect about you to companies or individuals that contract with us to perform service functions such as:

• Record keeping.
• Computer-related services.
• Good faith disclosure to regulators who have regulatory authority over the company.

Companies we hire to provide support services are not allowed to use your personal information for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of your personal information to the performance of the specific service we have requested. Notwithstanding the above, we will not release information about our customers or former customers unless we receive your prior written consent, we believe the recipient to be you or your authorized representative, or we are required by law to release information to the recipient.

We do not sell your personal information to anyone.

Regulation S-P Procedures

Information Security and Incident Response. We maintain written policies and procedures designed to protect the security and confidentiality of nonpublic personal information. Our program includes measures to:

• Identify and assess risks of unauthorized access or use.
• Implement and monitor safeguards appropriate to our business model.
• Detect, respond to, and recover from security incidents affecting customer information.

If we determine that nonpublic personal information has been, or is reasonably likely to have been, accessed or used without authorization, we will notify affected individuals as soon as practicable, and no later than 30 days after that determination, except where a delay is requested by law enforcement.

Service Provider Oversight. We require third-party service providers with access to nonpublic personal information to:

• Maintain appropriate protections.
• Notify us promptly of any unauthorized access or use.
• Cooperate in incident response and mitigation efforts.

Additionally, we conduct ongoing due diligence and monitoring of service providers consistent with regulatory requirements.

Scope of Individuals Covered. These protections apply to current and former clients, as well as to individuals who provide information to us in connection with a potential advisory or brokerage relationship, even if no account is opened or no contract is signed.

Privacy Notice Delivery under Regulation SP. We will provide initial privacy notices consistent with Regulation S-P. Consumers will receive notice before any non-public personal information is shared with third parties, and customers will receive notice before a customer relationship is established. When a relationship is initiated by telephone and providing notice beforehand materially delays a transaction, the notice may be delivered within the Customer Agreement Form, provided you consent. Annual privacy notices will be provided to all active customer accounts unless the privacy policy remains unchanged.

Confidentiality and Security

We maintain physical, electronic, and procedural safeguards to guard your personal information. We also restrict access to your personal and financial data only to our authorized associates who need these records. Furthermore, we will continue to adhere to the privacy policies and practices described in this notice even after your account is closed or becomes inactive.

California Privacy Rights Spam

California customers are entitled to request information relating to whether a business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like to make such a request, please submit your request in writing at the address information below.

SMS Privacy Policy

When you provide your mobile phone number to us, we collect and use that number solely to send you text messages you have consented to receive. These messages may include account updates, appointment reminders, service notifications, support communications, and, when permitted, promotional information. We do not sell, lease, or otherwise share your mobile number or SMS activity with third parties for their own marketing purposes. Your number may be shared only with our trusted service providers who assist us in delivering text messages, and they are required to protect your information and use it only for the services we request. We maintain administrative, technical, and physical safeguards designed to protect your mobile number and any information transmitted via SMS from unauthorized access or disclosure. However, because SMS is not a fully secure communication channel, we encourage you not to send sensitive or confidential information by text message. By providing your number, you represent that it is your own, that you are authorized to use it, and that you understand message and data rates may apply.

You may opt-out of receiving SMS messages at any time by replying “STOP” to any message we send. Once you opt-out, we will cease SMS communications except where required for security or transactional reasons. You may request assistance at any time by contacting us at (212) 887-2100.

Opt-Out Provisions

We have taken steps to assure that all third-party vendors have confidentiality clauses to protect your information. Should we not have such written agreements in place, then you have the option to “opt-out” of the sharing of this information. If you desire to opt-out for those instances that we do not have the confidentiality clause, or you do not wish to receive marketing materials from us, you should provide us with written instructions forwarded to Chief compliance Officer at the address set out above. Additionally, the law allows you to “opt-out” of only certain kinds of information sharing with third parties. We do not share personal information about you with any third parties that trigger this opt-out right. This means you are already opted out of these sharing situations.

To Contact Us

If you have questions regarding our privacy policy, please contact us at (212) 887-2100.

Last Updated: 31 December 2025