Use and Acceptance

This website (the “Site”), and any tools and/or services offered and/or provided by the William Paulstern Corporation through this Site, are offered to you conditioned upon your acceptance without modification of these Terms of Use. By using this Site, you agree to these Terms of Use. Please read these Terms of Use carefully. If you do not agree to these Terms of Use, you may not use this Site or any Offerings presented or provided through this Site.

Modification

We may change these Terms of Use from time to time without notice to you. You should review these Terms of Use each time you use this Site or a Service to make sure you agree to them. By using this Site or engaging in any of the activities described in these Terms of Use after changes have been made to these Terms of Use, you are agreeing to accept and comply with those changes.

Authorized Use; Copyrights and Trademarks

This Site and the Offerings may contain copyrighted works and trademarks and other proprietary material owned by us or our content providers. You may use the information available from this Site for informational purposes only. You may print copies of pages from this Site for your personal purposes, provided that each copy includes any copyright, trademark or service mark notice or attribution as they appear, on the pages copied. The availability of third party data from or through this Site is not to be used as a substitute for a license or services agreement directly with the relevant content provider. Except as stated above, you may not copy, reproduce, publish, post, transmit, display, store, sublicense, transfer or distribute material or images from this Site without our express written permission or that of our content providers, as applicable (“Permission”). You may not modify, alter, revise, paraphrase, omit, or change any material or images on or from this Site without Permission. You may not create derivative works, whether based in whole or in part upon the information on this Site or any portion thereof without Permission. You may not modify, amend, reduce the size of or in any way obscure any warning, notice, liability limitation or other license provision in material or images on or from this Site. Nothing contained on this Site and/or the Offerings should be construed as granting, by implication, estoppel or otherwise, any license or right in and to our trademarks or copyrighted material. The information contained in this Site is subject to change without notice.

We reserve the right to prohibit access to anyone whom we determine are violating these Terms of Use, restricting or inhibiting any other user from using or enjoying the Site, or whose conduct we reasonably determine may constitute a criminal offense, give rise to civil liability, or otherwise violate any applicable local, state, national, or international law.

Limited Availability, Eligibility

Not all Offerings mentioned on this Site may be available in all geographic areas. Your eligibility for particular products or services is subject to final determination by us and/or the applicable content provider.

Indemnification

You agree to indemnify and hold us and our third party content providers harmless from any loss, including reasonable attorneys’ fees, related to any cost, damages, claim or expense related to any content you submit, post to or transmit through this site, your use of the site or the services, your connection to the site, your violation of these terms of use, or any harm you cause another user.

Disclaimers

Some of the content on this site may be provided by third party content providers and users. We are a distributor and not a publisher of such content and have no control over it. Any opinions, advice, statements, services, offerings or other information given or provided by third parties (including merchants and licensors) are those of the respective authors of such content and not ours.

Although we use reasonable efforts to provide accurate and up-to-date information through this site, we and the content providers make no warranties or representations as to the accuracy, reliability, or comprehensiveness of content on this site and any service. The information contained on this site and any service is provided on an “as is” “as available” basis. To the fullest extent permitted by law, we disclaim all warranties of any kind, whether express or implied, with regard to information contained on this site and any service, including all implied warranties of merchantability, fitness for a particular purpose and non-infringement. We and the content providers cannot and do not guarantee or warrant that the files available for downloading from this site and any service will be free from infections or viruses, worms, trojan horses, or other code with contaminating or destructive properties. You hereby agree to release and hold us harmless from any and all claims, losses, expenses or damages relating to any disclaimed warranty described in this paragraph.

The information provided in any service or in this site is not investment or legal advice. Information received via this site or the services should not be relied upon for personal, legal or financial decisions and you should consult an appropriate professional for specific advice tailored to your situation. The information contained in this site, including the investor relations section (including, without limitation, stock quotes, stock charts, and sec filings) and any additional content is published solely for information purposes and is not a solicitation nor an offer to buy or sell any stock, mutual fund, or other security, nor should it be used in connection with any sale, offer for sale or solicitation of an offer to buy securities or any other instrument. Such information do not attempt or claim to be a complete description of the securities, markets, or developments referred to in the material. All expressions of opinion are subject to change without notice. Such information is obtained from internal and external sources which we considers reliable, but we have not independently verified such information and we do not guarantee that it is accurate or complete. We, our employees, and officers and directors, may from time to time have positions in the securities mentioned and may sell or buy such securities. Investment products are not bank deposits, are not guaranteed, and are subject to investment risks, including loss of the principal amount invested.

Some jurisdictions do not allow limitations on how long implied warranties last or the exclusion of certain implied warranties, so that these disclaimers and limitations may not apply to you. In such event, such disclaimers shall apply to the fullest extent permitted by law.

Trading

  1. Hours of Operation. Customer may place orders as and when permitted by William Paulstern for execution outside of regular trading hours except for official exchange and market holidays and those days on which William Paulstern chooses not to accept orders outside of regular trading hours. William Paulstern may, at any time and without notice, change or modify its hours of operation (including the hours during which it accepts orders outside of regular trading hours). If William Paulstern chooses to make such changes or modifications, this disclosure will also apply to the changed or modified hours. William Paulstern may, at any time and without notice, amend the terms that apply to orders accepted outside of regular trading hours.
  2. Risk Factors. Purchases and sales of securities outside of regular trading hours may entail special risks, including the following:
  3. Risk of Lower Liquidity. Liquidity refers to the ability of market participants to buy and sell securities. Generally, the more orders that are available in a market, the greater the liquidity. Liquidity is important because with greater liquidity it is easier for customers to buy or sell securities, and as a result, customers are more likely to pay or receive a competitive price for securities purchased or sold. There may be lower liquidity in extended hours trading as compared to regular market hours. As a result, customers order may only be partially executed or not executed at all.
  4. Risk of Higher Volatility. Volatility refers to the changes in price that securities undergo when trading. Generally, the higher the volatility of a security, the greater its price swings. There may be greater volatility in extended hours trading than in regular market hours. As a result, customers order may only be partially executed, or not at all, or customer may receive an inferior price in extended hours trading than customer would during regular market hours.
  5. Risk of Changing Prices. The prices of securities traded in extended hours trading may not reflect the prices either at the end of regular market hours or upon the opening of the next morning. As a result, customer may receive an inferior price in extended hours trading than customer would during regular market hours.
  6. Risk of Unlinked Markets. Depending on the extended hours trading system or the time of day, the prices displayed on a particular extended hour system may not reflect the prices in other concurrently operating extended hours trading systems dealing in the same securities. Accordingly, customer may receive an inferior price in one extended hours trading system than customer would in another extended hours trading system.
  7. Risk of News Announcements. Normally, issuers make news announcements that may affect the price of their securities after regular market hours. Similarly, important financial information is frequently announced outside of regular market hours. In extended hours trading, these announcements may occur during trading, and if combined with lower liquidity and higher volatility, may cause an exaggerated and unsustainable effect on the price of a security.
  8. Risk of Wider Spreads. The spread refers to the difference in price between what customer can buy a security for and what customer can sell it for. Lower liquidity and higher volatility in extended hours trading may result in wider than normal spreads for a particular security.
  9. Risk of Lack of Calculation or Dissemination of Underlying Index Value or Intraday Indicative Value (“IIV”). For certain derivative securities products, an updated underlying index value or IIV may not be calculated or publicly disseminated in extended trading hours. Since the underlying index value and IIV are not calculated or widely disseminated during the pre-market and post-market sessions, a customer who is unable to calculate implied values for certain derivative securities products in those sessions may be at a disadvantage to market professionals.
  10. Risk of exposure. The customer understands and agrees that based on the long-term business relationship principle he is limited to refund prior to achieving a minimum of 5 (five) trades.
  11. Eligible Securities. Most Nasdaq and certain other exchange-listed securities are eligible for trading outside of regular trading hours, although the individual markets may vary with respect to the availability of certain securities. It is possible, at any time, that trading in any number of these securities may not be available due to a lack of trading interest. William Paulstern reserves the right, at any time and without notice, to suspend trading in any or all securities outside of regular trading hours, with or without pending customer orders. If William Paulstern exercises that right, any outstanding orders that customer has entered will be cancelled, unless customer and William Paulstern have previously specifically agreed that they will be carried over to the next day.
  12. Order Types. William Paulstern will not accept market orders for trading outside of regular trading hours. Customer must enter all orders in round lots. William Paulstern is under no duty to accept odd or mixed lot orders.
  13. Orders. Orders entered for execution outside of regular trading hours must be specifically designated as such and, unless customer and William Paulstern specifically agree to the contrary, orders will not carry over from regular trading sessions. Orders not executed by the close of the extended hours trading session, on the day that William Paulstern receives them, will be cancelled, unless customer and William Paulstern specifically agree to the contrary.
  14. Handling of Orders. William Paulstern will attempt to have all orders received by it for execution outside of regular trading hours executed in a timely manner. However, because the bid and offer prices of orders reflected in quotations outside of regular trading hours are subject to change, there is no guarantee that customer’s orders will be executed. In addition, delays or failures in communications or other computer system problems may cause delays in, or prevent, the execution of orders. As with orders entered during regular trading sessions, William Paulstern may route customer’s order to an electronic communication network or other alternative trading system that, although operated independently of William Paulstern, may be an entity in which William Paulstern or one of its affiliates is an equity investor or has other financial interests. In addition, William Paulstern or one or more of its affiliates may decide to display orders or to trade with limit orders displayed by William Paulstern on customer’s behalf. These affiliates may or may not operate independently of William Paulstern.
  15. Cancellation or Change Requests. Customer may attempt to change or cancel orders placed outside of regular trading hours at any time so long as they have not been executed. Due to the risk of communication delays, it is possible that all or a portion of such orders may be executed before customer’s change or cancellation request is processed. Unless customer and William Paulstern specifically agree to the contrary, customer cannot change all or the unexecuted portion of customer’s order entered outside of regular trading hours to a regular trading session order, and all unexecuted orders placed outside of regular trading hours will be cancelled at the close of the trading session, on the day that William Paulstern receives such orders.
  16. Trade Settlement. The trade date for orders entered outside of regular trading hours will be the date of order execution. Such trades will normally settle in accordance with the customary settlement time applicable to the market in which orders were executed.

Severability

If a court determines that any Term of Use is illegal or unenforceable, then such term will be eliminated and the remaining Terms of Use will remain in force and effect.

Entire Agreement; Jurisdiction and Choice of Law and Forum

These Terms of Use constitute your entire agreement with us regarding this Site and any Services, and supersede all prior or contemporaneous communications and proposals, whether electronic, oral or written between you and us with respect to the Site or the Services. This Site and/or the Services may not comply with legal requirements of foreign countries, therefore the Site, its contents and the Services are intended only for access and use by Hong Kong residents and are presented solely as a service to visitors and/or subscribers located in Hong Kong and its territories. These Terms of Use are governed by and construed in accordance with the laws of Hong Kong, without giving effect to any principles of conflicts of law. You expressly and irrevocably agree that exclusive jurisdiction and venue for any claim or dispute with us, our employees, contractors, officers, directors and content providers or relating in any way to your use of this Site or the Offerings resides in the state courts in Hong Kong and you further irrevocably agree and expressly and irrevocably consent to the exercise of personal jurisdiction in those courts over any action brought under these Terms of Use. We and you hereby waive the right of trial by jury in any action arising out of or related to the Site, Services or these Terms of Use.

Submissions

You agree to provide true, accurate, current and complete information about yourself when you elect to provide personal information to us. You also agree to maintain and promptly update any such information to keep it accurate. Other than information addressed under our Privacy Policy, any and all comments, suggestions, ideas, graphics, or other information that you transmit or post to the Site becomes and will remain our property and may be used by us anywhere, anytime and for any reason whatsoever. Except as may be provided in the Privacy Policy, any information or materials submitted to us will be treated as non-confidential and non-proprietary, and we will not have any obligation to use or evaluate any information we receive from you. We will not have to pay you or anyone else for using any ideas or other materials that you may transmit to or post on the Site.

Protecting Your Information

We utilize reasonable security technologies to protect sensitive information. However, the security of this information depends in part on the security of the computer you use to communicate with us and the security provided by your internet access services provider. We are not responsible for the security of your internet access services provider; you should review the security and privacy policies of your internet access services provider carefully. Information that you access via this Site may be stored on your computer during your session for your convenience. If others have access to your computer, they may be able to access this information. We are not responsible for the security or privacy of information communicated to or from such a computer. Finally, you should keep any correspondence you receive relating to this Site or the Offerings (including, but not limited to, registration information, emails, order information, or any other information) confidential and in a safe place.

Inspection, Correction and Removal of Information

We will use reasonable efforts to allow you to review, correct or update the information that you have provided to us at any time. Please note that because of back-up systems and records of deletions, it may not be possible for us to locate and remove from our systems residual information that you have provided to us.

We cannot require third parties to change information that has been disclosed to them with your consent. To modify this information, you will have to go directly to the relevant third party.

Online Security

The Internet is one of the most powerful communication tools available, making it possible to share information instantly, any time of the day or night, around the globe.

Criminals have capitalized on the broad power and wide availability of the Internet and electronic mail (e-mail) to defraud unsuspecting people. It is critical that each of us maintain constant vigilance over the way we use the Internet and all forms of electronic communication.

William Paulstern Corporation maintains active oversight of all of our systems as part of our efforts to protect the security and privacy of client information.

If you have any concerns or questions, please contact your William Paulstern representative.

William Paulstern does not contact its clients or anyone else by e-mail to confirm credit card or financial transactions, or to confirm or request personal account information or any other type of sensitive information.

Protect Yourself

To help protect yourself and your personal data, do not trust any e-mail communications that request your personal information.

Criminals can be convincing. They make their fraudulent e-mails look like they come from legitimate sources. They publish fake websites that use designs, information and programming stolen from their rightful owners. Cyber criminals use methods to impersonate you over the phone to arrange funds transfers, or imitate communications from the financial institution to verify transactions, or initiate other changes to your account. Don’t fall for their ploys.

E-mail and Website Scams

E-mail is by far the most popular way for criminals to try to get your attention — and your personal information. An e-mail may direct you to a website designed and operated by criminals to trick you into revealing such information. Therefore, treat e-mail from someone you don’t know the same way you would treat a telemarketing call from someone you don’t know: don’t necessarily believe what you’re being told.

Fraudulent e-mails and websites are created every day to attempt to steal personal information. It’s called “phishing” — a variation of the word “fishing.” There are limitless variations of these online scams, so the best defense is education and a healthy dose of skepticism. A few misleading and deceptive techniques in use include the following:

  • The e-mail or website may appear to be genuine.
  • It may include a logo that appears legitimate.
  • It may ask you to click on a link to go to a website — the website address may, at first glance, appear legitimate and imply importance.
  • The e-mail or website may ask for you to supply account numbers, personal identification numbers (PINs), passwords or credit card numbers.
  • The e-mail or website may even already contain some of this information and is asking you to confirm the data.
  • You are right to be suspicious of any e-mail or website asking you to supply or confirm any personal information.

As technology and one’s ability to detect these scams improves, so, unfortunately, do the criminals. The latest attacks do not even require you to do anything. Merely opening the e-mail can launch “hidden” software — a virus, “spyware” or other malicious code — that will download to and reside on your computer. Should they go undetected, any of these programs could compromise your computer in a variety of ways, including stealing private information, redirecting your Web surfing to unscrupulous sites and transmitting information that you type on your computer directly to the criminals. Therefore you should delete all unwanted and potentially fraudulent e-mails without opening them.

Some fraudulent e-mails, spear-phishing attempts for example, can be very well done and very convincing. These are often created by more sophisticated and more determined criminals who are highly motivated to succeed. More generally, however, most fraudulent e-mails and websites established for fraud may frequently be characterized by the following:

  • Misspellings and other typographical errors
  • Poor grammar
  • Urgent messages in the e-mail subject line
  • Random characters in the e-mail subject line or body
  • “Fuzzy” logos, or logos that are distorted

Tricks of the Trade

There is a number of common e-mail scams of which you should be aware. While this list is by no means exhaustive, recent e-mail tricks include:

  • Creating a sense of panic. E-mails threatening loss of account access, loss of credit, foreclosure, etc., are trying to get you to panic enough to lose your common sense and fall for their scam. Don’t panic; when in doubt, call your financial institution.
  • Referencing a recent transaction. Vaguely worded e-mails referring to a “recent transaction” that you need to go online and verify, or for which you need to provide additional account information, are also just trying to get you to fall for their scam.
  • Confirming your account information. It’s possible that the criminals think they already have your account numbers, password, etc., and all they need is your confirmation. They could have guessed, they could have bought it, they could have stolen it. Don’t give them the help they need to use it. Do not respond to confirmation-of-information requests received via an e-mail that you are not expecting or that could possibly be fraudulent. This includes both not responding via e-mail and not visiting a website to confirm the information.
  • You’re a winner! “Just send money to cover the costs/fees/taxes and you can claim your prize.” If you do respond to this solicitation, the thief will have your money as well as your credit or debit card information if you pay online, or your checking account number and bank routing information if you pay by check. A legitimate contest will never make you pay to receive the prize.
  • Your donation is needed. Many criminals act like they are actually charities and request your donations, appealing to your emotions and taking advantage of tragedies and natural disasters. Be careful when making charitable donations. Many legitimate organizations now accept donations online. But exercise caution and only donate via a non-profit organization’s website directly, or if you are absolutely sure of the company through which you are donating.

Website Spoofing

“Spoofing” is another trick used by criminals. Criminals steal a website’s code — the technical programming that makes the website work — and use it to create a fake website that “spoofs” or appears to be the legitimate site.

The difficulty for unsuspecting consumers is that these sites look legitimate. To help protect yourself, be aware of how you’re accessing the site.

  • Don’t follow a link in an unsolicited e-mail if you have any doubts about the sender (see “phishing”, above).
  • Type all website addresses carefully, or use Favorites or Bookmarks to store frequently accessed sites — especially financial-related sites. Misspelling, even by one letter, the address of the website you are trying to access may send you to an incorrect, possibly fraudulent, website.

Lottery / Sweepstakes Letter Scams

If you receive a letter, accompanied by a check with a William Paulstern brand, that claims you have won a lottery, a sweepstakes, have been chosen to be a paid “secret shopper” or a similar variation of a popular contest, be advised that these are scam letters and fraudulent checks. If you contact the sender as requested, you will be instructed to negotiate the check and forward the sender money through a wire transfer or money order. Please do not negotiate these checks, as they are not authentic William Paulstern checks. If you receive one of these letters and/or checks, you should report it to your local Postal Inspection Service.

Corporate Account Takeover

Corporate account takeovers, once associated mostly with large corporations, have started to target municipalities, smaller businesses, and non-profit organizations. Thousands of businesses, small and large, have reportedly fallen victim to this type of fraud. To obtain access to business financial accounts, cyber criminals often target employees and cause the targeted individual to download and spread malicious software (or “malware”) which in turn steals their log-in credentials. Cyber criminals typically will accomplish this by getting you to perform some action such as open an e-mail attachment, accept a fake friend request on a social networking site, visit an already compromised legitimate website, or plug an infected USB drive into your system. All of these can install malware on your computer.

Some recent methods used to trick employees into opening the attachment or clicking on the link, have included making the e-mail appear come from a legitimate business, for example:

  • UPS (e.g., “There has been a problem with your shipment.”)
  • Financial institutions (e.g., “There is a problem with your banking account.”)
  • Better Business Bureaus (e.g., “A complaint has been filed against you.”)
  • Court systems (e.g., “You have been served a subpoena.”)

Cyber criminals may try to take advantage of some current event, such as a natural disasters or major sporting events. They may use credentials stolen from company websites or co-workers or executives and design the e-mail to look like it comes from a trusted source.

Once they are able to get you to download their malware, they can easily steal your account login credentials and then be able to electronically steal money from your business accounts through unauthorized wire transfers and ACH payments.

What You Can Do

Report any problems regarding William Paulstern to your customer service representative.

If you should become a victim of identity theft, you can take the following actions to help you protect your personal and financial interests:

Contact your bank and credit card issuers to ensure that:

  • Access to your accounts can be protected
  • All transactions are actually yours
  • Your address information has not been changed
  • Your PINs have not been changed
  • New checks have not been ordered by the identity thief

File a police report with your local police department and provide the facts and circumstances surrounding your loss. Obtain a police report number with the date, time, police department, location and name of the police officer taking the report or involved in the subsequent investigation. Having a police report on file will often facilitate your dealings with insurance companies, banks, credit card agencies, and commercial establishments that may be parties involved in fraudulent transactions. The police report may initiate a law enforcement investigation into the loss with the goal of identifying, arresting, and prosecuting the offender and possibly recovering your lost items. The police report will also help provide immediate clarification should someone assume your identity and be arrested for criminal activity using your name and biographical data.

Business and personal customers should employ best practices to secure computer systems in their homes and business including, but not limited to:

  • Utilize strong passwords with at least 10 characters that include a combination of mixed case letters, numbers and special characters
  • Do not share with others usernames and passwords for online banking systems
  • Use a different password for online banking sites than you might use for e-mail and other Internet activities
  • Verify use of a secure session (https not http) in the browser for all online banking
  • Do not “script” usernames and passwords for online banking to allow for automatic logins
  • Install commercial anti-virus, desktop firewall, and intrusion detection software on all computer systems and apply updates regularly
  • Ensure computers are patched regularly, particularly operating system and key applications with security patches
  • Always activate the screensaver locking feature when you need to leave your computer unattended
  • Limit administrative rights on users’ workstations to help prevent the inadvertent downloading of malware or other viruses — create limited user accounts for daily use
  • Where practical, carry out online banking activities from a stand-alone and locked down computer from which e-mail and Web browsing are not possible
  • Never access bank, brokerage or other financial services information from public kiosks such as those found at Internet cafes, public libraries, and airports
  • Educate your staff on this type of fraud scheme
  • Configure routers and firewalls to deny unauthorized access to your computer or network
  • Change the default passwords on all network devices regularly
  • Block pop-ups
  • Keep abreast of the continuous cyber threats that occur
  • Engage IT support staff if staff reports any unexplained changes in the performance or behavior of computers, they experience unexpected system shutdown and restarts, or see new and unexpected toolbars or menu items
  • Make sure your employees know how and to whom to report suspicious activity to within your company and at your financial institution
  • Ensure your contingency plan addresses the need to recover systems suspected of compromise by malware, not just data corruption and catastrophic system/hardware failure
  • Consider whether other company or personal data may have been compromised
  • Contact your financial institution for more information

Immediately notify us of any suspicious transactions, particularly ACH or wire transfers.

E-mail Security

William Paulstern actively works to protect the privacy and data integrity of sensitive information while it is in our possession and control. In the course of providing services, we may exchange information with clients or their authorized representatives which is sensitive and confidential. In order to protect this information, William Paulstern requires Highly Confidential Information (HCI), and in some cases other types of sensitive information, to be encrypted when transmitted over an open unsecured network.

William Paulstern provides two methods of encryption for electronic messages containing HCI sent to external recipients.

  • Transport Layer Security (TLS)
  • William Paulstern Secure Messaging Portal

Transport Layer Security is the primary and preferred method of encryption for William Paulstern. This method of encryption allows e-mail to be automatically secured with no additional steps required by the sender and recipient. TLS requires our external partner organizations to have both a TLS capable infrastructure and a valid digital certificate for encryption. Once established, this method is the most convenient for all users and provides seamless encryption for e-mail and attachments. TLS encrypts e-mail message between servers and is designed to protect confidentiality and data integrity and is a widely recognized standard issued by the Internet Engineering Task Force (IETF) for securing transmitted data.

William Paulstern Secure Messaging Portal is the alternative secure encryption tool which is utilized when an external partner does not have TLS capability. The portal encapsulates a message and its attachments into an encrypted message. Once protected, the encrypted message is sent to recipients as an attachment to a plain text e-mail. The recipient uses a self-created, pre-registered password to access the notification and any attachments. This guide provides step-by-step instructions on how to register and use William Paulstern’s Secure Messaging tool.

Note: When accessing any third-party/external sites that may be linked above, you will leave the William Paulstern website. These sites are not controlled or endorsed by William Paulstern, and William Paulstern is not responsible for the contents, operation or security of these sites.