MFB Privacy Policy

We may collect personal information from the following sources:

Account applications and related forms: Name, address, date of birth, social security or tax ID, employment, and financial information.

Transactions and interactions: Trading history, product usage, account communications, IP addresses, device fingerprints.

Third parties: Credit reporting agencies, background verification providers, or other service providers.

Online activity: Website usage, functional and performance cookies, and analytics. Marketing preferences are collected only for non-U.S. clients who provide explicit consent.

We do not collect more personal information than necessary for providing our services and marketing communications.

We may use personal information for purposes permitted by law and industry practice, including: opening and servicing your account with our affiliated FCM(s); communicating with you about services, promotions, or account-related matters; complying with legal, regulatory, or contractual obligations; improving our services through analytics, reporting, and research; marketing products or services only to non-U.S. clients who have provided explicit consent, and to U.S. clients only through affirmative opt-in communications (e.g., email newsletters).

Note: The FCM that clears your account remains the primary controller of account data for regulatory, legal, and recordkeeping purposes.

We may share your personal information in the following circumstances: with affiliated FCMs to open, maintain, or service accounts; with service providers acting on our behalf, under confidentiality agreements; with regulators or law enforcement as required by law or for fraud prevention; with marketing partners only for communications you have consented to (non-U.S. customers only), and only where such partners act as service providers under contractual confidentiality and data-use restrictions and may not use personal information for independent purposes; with other third parties only as required by law or directed by you.

We do not sell your personal information.

We use cookies and similar technologies to: enhance website functionality and performance; track website usage for analytics purposes (aggregated and anonymized); customize content, where explicitly consented.

We may use cookies or tracking for remarketing, targeted advertising, or behavioral profiling.

You may manage cookies through your browser settings. Some website features may not function properly if cookies are disabled. Please see our Cookie Policy on this website. You can also use the Cookie Policy link in the site footer.

If you are a resident of the EEA, UK, or other jurisdictions with privacy laws (e.g., GDPR, UK GDPR): You have rights to access, correct, or request deletion of personal information held by MFB, to the extent legally permissible. Requests related to account-level information may be coordinated with the FCM, as the FCM retains primary control over account data. You may withdraw consent for marketing communications at any time.

For further inquiries regarding privacy rights, please contact: support@talero.com.

By providing your contact information, you consent to receive communications from MFB regarding: account service updates; products, services, and marketing (with consent); educational content; opt-in marketing communications.

You may opt-out of marketing communications at any time without affecting your account or transactional communications.

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

Personal information is retained as long as necessary for business, legal, and regulatory purposes. Retention periods may be extended for litigation, investigations, or regulatory obligations.

MFB may update this Privacy Policy from time to time. Updated policies will be posted on our website and become effective immediately upon posting.

For questions about this Privacy Policy or your personal information:

MFB Capital, LLC

108 Lakeland Ave.,

Dover, DE 19901

support@talero.com

Effective date: March 17, 2026. This Addendum supplements the MFB Privacy Policy and applies to clients or prospective clients who are residents of the European Economic Area (EEA) or the United Kingdom (UK).

For account-level data, the clearing FCM remains the primary controller of personal data for regulatory and legal purposes. MFB acts as a data processor or joint controller only for personal information collected directly for marketing, educational, or communication purposes.

MFB may process your personal information under GDPR/UK GDPR for the following purposes: to perform pre-contractual steps or provide services requested by you; for marketing communications, analytics, and business operations, provided your rights are not overridden; where required (e.g., for marketing emails or targeted communications).

You may withdraw consent at any time for marketing purposes without affecting your account or other service relationships.

Under GDPR/UK GDPR, you have the following rights with respect to personal information processed by MFB: request access to personal information we hold about you; request correction of inaccurate or incomplete information; request deletion of personal information, subject to legal and contractual obligations; request restrictions on certain processing activities; object to processing for marketing purposes or on grounds relating to your particular situation; request transfer of personal information in a structured, commonly used, and machine-readable format.

Requests related to account-level data may be coordinated with the FCM.

Personal data collected for marketing or communication purposes may be transferred outside the EEA or UK. Where such transfers occur, and are required by law, MFB ensures appropriate safeguards, such as standard contractual clauses, to protect your personal data.

We retain personal data only as long as necessary for the purpose it was collected or as required by law. Marketing and communication data are generally retained until consent is withdrawn or the client relationship ends.

You may contact us at support@talero.com regarding any concerns about personal data processing. You also have the right to lodge a complaint with your local Data Protection Authority in the EEA or UK.

This Addendum may be updated to reflect changes in applicable law, business practices, or FCM arrangements. The latest version will always be posted on the MFB website.

This addendum supplements the MFB Capital, LLC (“MFB,” “we,” “us,” or “our”) Privacy Policy and applies only to individuals who are residents of the State of California, in accordance with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”).

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). We may also collect aggregated or de-identified information that does not identify you; to the extent such information is associated with Personal Information, it will be treated as Personal Information under this section.

Categories of personal information collected. MFB may collect the following categories of Personal Information: identifiers, such as name, postal address, email address, telephone number, account name, IP address, or other similar identifiers; personal information categories described in California Civil Code §1798.80(e), such as name, contact information, signature, and, where applicable, financial or account-related information; commercial information, such as records of products or services obtained or considered; internet or other electronic network activity information, including browsing history, interactions with our website, and information regarding a consumer’s interaction with our online services; geolocation data, such as general location derived from IP addresses; professional or employment-related information, where voluntarily provided; inferences, drawn from any of the information above to create a profile reflecting preferences or characteristics.

We do not knowingly collect sensitive personal information except where necessary to comply with legal, regulatory, or contractual obligations, and we do not use sensitive personal information for purposes requiring a right to limit under the CPRA.

If we intend to collect additional categories of Personal Information, we will provide notice at or before the time of collection.

We collect and use Personal Information for the following business and commercial purposes, as permitted by law: providing, operating, and maintaining our services, including account-related activities where applicable; communicating with you regarding services, operational matters, or inquiries; complying with applicable laws, regulations, regulatory requests, and legal obligations; detecting security incidents, preventing fraud, and protecting against malicious, deceptive, or illegal activity; debugging and improving functionality of our systems and services; conducting internal research, analytics, and service improvement; protecting the rights, property, and safety of MFB, our clients, and other parties.

We will not use Personal Information for materially different, unrelated, or incompatible purposes without providing you with notice.

We may collect Personal Information from the following sources: directly from you, when you provide it through forms, communications, or interactions with us; automatically, through your use of our website or online services (e.g., cookies, analytics tools); service providers, vendors, or professional advisors acting on our behalf; affiliates or counterparties, where applicable and permitted by law; government or regulatory authorities, as required or permitted by law.

We may disclose Personal Information for a business purpose to the following categories of recipients: service providers and vendors who perform services on our behalf under contractual confidentiality obligations; professional advisors, such as legal, accounting, auditing, or compliance consultants; regulatory authorities, law enforcement, or government agencies, where required or permitted by law; third parties in connection with a corporate transaction, such as a merger, reorganization, or sale of assets.

Within the last twelve (12) months, we have not knowingly sold Personal Information in exchange for monetary consideration.

MFB does not sell Personal Information as that term is traditionally understood. However, certain disclosures of Personal Information through cookies or similar technologies may be considered a “sale” or “sharing” under California law if such information is disclosed for cross-context behavioral advertising.

You have the right to opt out of any such sale or sharing, to the extent applicable. MFB does not have actual knowledge that it sells or shares the Personal Information of minors under 16 years of age.

If you are a California resident, you have the following rights under the CCPA/CPRA, subject to certain exceptions: right to know the categories and specific pieces of Personal Information we have collected about you; right to access Personal Information we hold about you; right to delete Personal Information we collected from you, subject to legal exceptions; right to correct inaccurate Personal Information; right to opt out of the sale or sharing of Personal Information, if applicable; right to non-discrimination for exercising your privacy rights.

We will not discriminate against you for exercising any of your CCPA/CPRA rights.

To exercise your California privacy rights, you must submit a verifiable consumer request. The request must provide sufficient information to allow us to reasonably verify your identity and understand the scope of your request. We may request additional information if necessary to verify your identity.

Requests may be submitted by contacting us at:

Email: support@talero.com

Address: 108 Lakeland Ave., Dover, DE 19901

We will respond to verified requests in accordance with applicable law.

We retain Personal Information for as long as reasonably necessary to fulfill the purposes for which it was collected, including compliance with legal, regulatory, accounting, or reporting obligations. Retention periods may be extended where required for investigations, litigation, or regulatory matters.

We reserve the right to modify or update this California Privacy Rights section at any time. Any changes will be effective upon posting of the revised Privacy Policy. Your continued use of our services following such updates constitutes acknowledgment of the revised terms.