Consent to Identity Verification Services

Before HypeStrat Markets LLC (the “Firm”) opens your account, federal law requires it to verify your identity and check you against government lists. The Firm uses outside providers for part of this work. This document explains what is collected, who receives it, how long it is kept, what you authorize, and how to revoke your consent.

1Why the Firm verifies your identity

1.1Futures commission merchants must comply with the Bank Secrecy Act (17 CFR 42.2) and run a customer identification program that verifies each customer’s identity, to the extent reasonable and practicable, so that the firm forms a reasonable belief that it knows the customer’s true identity (31 CFR 1026.220(a)(2)).

1.2The Firm must also check whether you appear on government lists of known or suspected terrorists or terrorist organizations (31 CFR 1026.220(a)(4)), and must comply with U.S. sanctions law.

2What the Firm collects

(a)Identifying information: your name, date of birth, residential street address and taxpayer identification number (for most customers, a Social Security number) (31 CFR 1026.220(a)(2)(i));

(b)Identity document: images of an unexpired government-issued photo identity document, such as a driver’s license or passport;

(c)Selfie and liveness check: a photo or short video of your face, used to confirm that you are the person on the document and are present (section 5);

(d)Device and session data: such as IP address, device type and approximate location, used to detect fraud;

(e)Wallet information: the address of each Wallet you register and its transaction history on public blockchains; and

(f)Application information: the information NFA Compliance Rule 2-30 requires (income, net worth, liquid net worth, age and trading experience).

3How your identity is verified and screened

3.1Documents. The provider checks that your identity document is genuine and unexpired and that its details match what you entered.

3.2Other sources. The Firm or its provider may compare your information with information from consumer reporting agencies, public databases and other sources (31 CFR 1026.220(a)(2)(ii)(B)).

3.3Screening of you. You are screened against U.S. and other sanctions lists, government lists of known or suspected terrorists, lists of politically exposed persons, and adverse media.

3.4Screening of your Wallet. A blockchain analytics provider reviews the history of each Wallet you register for exposure to sanctioned persons, stolen funds and other illicit activity, before the Wallet is registered and afterwards, including when you deposit or withdraw.

3.5Repeat checks. The Firm may repeat these checks while you have an account, for example when your details change, on a regular schedule, or when a list is updated.

3.6Decisions. Results are reviewed under the Firm’s procedures. Where a check is not conclusive, a member of the Firm’s compliance staff decides, and may ask you for more information or documents.

4Who receives your information

4.1Service providers. The Firm shares your information with:

(a)An identity verification provider, which verifies your identity document, matches your selfie and screens you; and

(b)A blockchain analytics provider, which screens your Wallet addresses.

These providers act on the Firm’s behalf under written contracts that prohibit them from disclosing or using your information except to carry out the services for the Firm (17 CFR 160.13).

4.2Others. The Firm may also share information where the law permits or requires, for example with regulators and law enforcement, with its auditors and attorneys, and to prevent fraud (17 CFR 160.15). The Firm does not sell your personal information.

4.3Privacy Notice. The Firm’s Privacy Notice, given to you under 17 CFR Part 160, describes its privacy practices and your choices.

5Biometric information

5.1What and why. To confirm that you are the person shown on your identity document, the identity verification provider creates a template of your facial geometry from your selfie and from the document photo and compares the two. This biometric information is used only to verify your identity and prevent fraud.

5.2Who holds it. The identity verification provider holds it for the Firm. It is not sold, leased, traded or otherwise used for profit, and it is not disclosed except to complete a verification you asked for, where the law requires, or under a valid warrant or subpoena.

5.3How long. Biometric information is permanently destroyed when the purpose for which it was collected has been met, or within three years of your last interaction with the Firm, whichever comes first, unless the law requires it to be kept longer. The Firm’s written retention policy for biometric information is published at the Firm’s website.

5.4Your written release. By signing this consent, you give your written release for the collection, storage and use of your biometric information as this section describes (740 ILCS 14/15(b)).

6How long the Firm keeps your information

6.1Identifying information is kept for five years after your account is closed. Records of the documents relied on, the verification methods and results, and how any discrepancy was resolved are kept for five years after they are made (31 CFR 1026.220(a)(3)(ii)). Other records are kept as CFTC Regulation 1.31 requires.

6.2Providers keep information only as long as their contracts with the Firm and the law allow.

6.3Your information is protected by the Firm’s safeguards policies (17 CFR 160.30).

7What you authorize

By signing, you authorize the Firm and its providers to:

(a)Collect the information in section 2 and use it to verify your identity, screen you and your Wallets, and prevent fraud;

(b)Obtain information about you from consumer reporting agencies and other sources to verify your identity; this consent is your written instruction for that purpose (15 U.S.C. 1681b(a)(2));

(c)Share your information with the providers named in section 4 for those purposes;

(d)Collect, store and use your biometric information as section 5 describes; and

(e)Repeat these checks while you have an account.

8If your identity cannot be verified

If the Firm cannot form a reasonable belief that it knows your true identity, it may decline to open your account, restrict the account while it tries to verify you, or close it (31 CFR 1026.220(a)(2)(iii)). The Firm may be required by law to report certain matters to government authorities and may be prohibited by law from telling you that it has done so.

9How to revoke your consent

9.1You may revoke this consent at any time by email to the contact address the Firm gives you, by secure message in your account, or by letter to the contact address the Firm gives you.

9.2Because the law requires verification and ongoing screening, the Firm cannot open or keep an account without this consent. If you revoke it, the Firm will close your account under the Customer Agreement once your positions are closed or transferred.

9.3Revoking stops future checks and any further collection of biometric information. It does not undo checks already made, and it does not require the Firm to delete records the law requires it to keep (section 6). Biometric information is destroyed as section 5.3 describes.

Your consent

I have read this consent and the notice above, and I authorize the checks it describes.

You accept this document electronically on the application page. The version you accepted and the time are recorded.