Updated 2/25/2025 

Welcome to our website. We value your privacy and are dedicated to protecting your personal data and financial information. This privacy policy outlines how we collect, use, store, and protect your personal data and financial information, and your rights concerning this data. We do not share your data with third parties for marketing or promotional purposes.

1. Data Sharing and Disclosure 

We do not share your personal data or financial information with third parties for marketing or promotional purposes. We may share your data with third parties or outside companies only in the following circumstances:

• Financial Service Providers: Third-parties or outside companies that help us process your transactions or service your account(s). One such company is the clearing firm, which processes your transactions and acts as the account custodian. Other companies include Realta Equities Inc, Realta Investment Advisors LLC, plus outside third-party administrators, investment advisors, asset managers, variable annuity or insurance companies, fixed annuity or insurance companies, mutual fund companies and the like. We may also provide information to outside service providers that print and mail your account statements. Any outside company or third-party provider must limit their use of your information to the purpose for which it was provided.
• Service Providers: With third-party service providers who perform functions on our behalf, such as  IT service providers, data storage providers, and telecom service providers.
• Legal Obligations: When required by law or to respond to legal processes. 
  Ashira Financial LLC may also provide your personal data and financial information when permitted or required by law or regulation. Examples include providing information in response to a subpoena or court order, to cooperate with regulators, governmental authorities or law enforcement authorities, or in response to a request from a consumer reporting agency.
• Protection: To protect our rights, property, and safety, or that of our customers and others.
• Additionally, Ashira Financial LLC may also provide your personal data and financial information when permitted or required by law or regulation.

• Outside of these circumstances, we will not provide your personal information to third parties unless you have specifically asked us to do so.
  
  

2. Data We Collect 

We collect various types of personal data and financial information from you and about you. Some of this information is collected to satisfy certain legal and regulatory requirements, while other information is collected so that we can service your account(s) effectively, including:

• Identity Data: Full Name, Social Security Number.
• Contact Data: Email address, phone number, billing and delivery address
• Financial Transactions: Including securities purchased and sold, fund transfers, account balances, insurance accounts/products and other account activities.
• Other Personal Information: Employment, Income, Net Worth, Investment Experience, Family information and other information to service you effectively.
• Business and Employees: To service and offer Group Benefits and Employee Benefits, or other services to your business and/or company.
• Technical Data: IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. 
• Usage Data: Information about how you use our website, products, and services. 
• Marketing and Communications Data: Your preferences in receiving marketing from us and your communication preferences.
  
  

3. Methods of Data Collection 

We collect personal data and financial information using various methods, including:

• Direct Interactions: When you provide your personal data and financial information in person, over the phone, through mail, email, website or online technology when you fill out forms and account applications, create an account, subscribe to our services, request marketing materials, or give us feedback. 
• Automated Technologies: As you interact with our website, we may automatically collect technical data about your equipment, browsing actions, and patterns. We collect this data using cookies, server logs, and other similar technologies
• Consumer Reporting Agencies: We may also collect information from consumer reporting agencies.
  
  

4. How We Use Your Personal data and financial information

We use your personal data and financial information for the following purposes:

• Service Provision: To effectively perform the contract we are about to enter into or have entered into with you. 
• Customer Support: To respond to your inquiries and provide support.
• SMS Program: If you opt into our SMS program, we will send you messages regarding our services, updates, policies, and promotional offers. You will receive messages about product updates, service notifications, and special offers. You can opt-out at any time. 
• Marketing and Communications: To send you marketing materials and communicate with you about our services. 

Prospecting: To analyze your data to understand your preferences and prospects for new clients. 

5. What We Do To Protect Your Personal Information: Data Storage, Maintenance, and Protection 

We implement appropriate security measures to protect your personal data and financial information from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. These measures include: 

• Data Encryption: Encrypting personal data and financial information to protect it from unauthorized access. 
• Access Controls: Limiting access to personal data and financial information to authorized personnel only to service you and/or your business/company. All employees are trained regarding the policies and procedures encompassed by this privacy policy.
• Regular Security Assessments: Conducting regular security assessments to identify and mitigate potential vulnerabilities.
  
  

6. Your Rights You have the following rights regarding your personal data and financial information: 

• Access: You can request access to the personal data and financial information we hold about you. 
• Correction: You can request correction of any incomplete or inaccurate data we hold about you. 
• Erasure: You can request deletion of your personal data and financial information where there is no good reason for us to continue processing it. 
• Objection: You can object to the processing of your personal data and financial information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground. 
• Restriction: You can request restriction of processing of your personal data and financial information.
  
  

7. Opt-Out Options and Mobile Information

You have the right to opt out of receiving marketing communications from us at any time by: 

• SMS: Replying “STOP” to any SMS message you receive from us. Email: Clicking the “unsubscribe” link in any email you receive from us. 
• Account Settings: Updating your preferences in your account settings on our website.

More on mobile information usage, collection, and privacy

• Our SMS program provides updates, notifications, and promotional messages related to our services. By subscribing to our SMS program, you consent to receive SMS messages at the phone number provided. Message frequency may vary based on your interaction with our service.
• We do not share your mobile information with third parties or affiliates for marketing or promotional purposes. Additionally, all the categories of personal data and financial information mentioned above exclude text messaging originator opt-in data and consent. This information will not be shared with any third parties under any circumstances. However, we may share your data with trusted service providers who assist us in operating our SMS program, provided they agree to keep your data confidential and use it solely for the purpose of providing services on our behalf.
• You have the right to access, correct, verify, or remove your personal information at any time. To manage your information, please contact us at 301.323.8767
• Opt-Out Option: If you wish to opt-out of receiving SMS messages, you may do so at any time by replying “STOP” to any of our messages or by contacting us directly at 301.323.8767. Opting out will not affect your other interactions with our services.
  
  

8. Securities Investor Protection Corporation (SIPC)

Customers may obtain information about the Securities Investor Protection Corporation (“SIPC”), including the SIPC Brochure, by contacting SIPC via its website at www.sipc.org or by telephone at (202) 371-8300.

9. Financial Industry Regulatory Authority (FINRA) Public Disclosure

In accordance with the Financial Industry Regulatory Authority (FINRA) Investor Education and Protection Rule, we are providing the following information: 1) The FINRA Public Disclosure Hotline telephone number is (800) 289-9999, and 2.) the FINRA website address is www.finra.org. A copy of an investor brochure that includes information concerning the FINRA Public Disclosure Program can be obtained by calling the Public Disclosure Hotline or visiting the FINRA website.

10. Anti-Money Laundering

The USA Patriot Act requires broker-dealers such as Center Street Securities, Inc. to collect certain identification information from all customers and verify their identities.

11. Changes to this Privacy Policy 

We may change this Privacy Statement from time to time when necessary to reflect changes in our Services, how we use personal information, or the applicable law. If we make changes, we will revise the “Last Updated” date at the top of the statement. If we make material changes, we will provide you with notice or obtain consent regarding such changes as may be required by law. We encourage you to review the Privacy Statement whenever you access the Services or otherwise interact with us to stay informed about our privacy practices and the ways in which you can exercise choice over these practices. The practices described in this Privacy Statement are subject to applicable laws in the locations in which we operate.

12. Questions Regarding this Privacy Policy 

For questions regarding Ashira Financial LLC’s privacy policy, text or call 301.323.8767.