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| EDI Financial PRIVACY NOTICE |
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EDIF is committed to safeguarding your personal information provided to us by you. This notice, required under SEC Regulation S-P, describes our privacy policy and how we handle and protect your personal information. The provisions of this notice apply to all present and former EDIF customers. We collect personal information about you so that we can make recommendations about products and services we offer that may be of interest to you. We collect nonpublic personal information from the following sources:
We restrict access to your personal information to those employees who need to know that information in order to provide products and services to you. Our employees are required to maintain and protect the confidentiality of your personal information and must follow established procedures to do so. To comply with applicable laws and regulations, we maintain physical, electronic, and procedural safeguards that comply with applicable laws and regulations to protect your personal information. We may share your personal information described above with our affiliates for business purposes, such as marketing new products and services, servicing your account, and as permitted by law. Our affiliates are companies controlled or under common control of our holding company. The information we share with affiliates may include the information described above (such as name, address, income and information related to your account with EDIF. We may share the personal information described above for business purposes relating to your personal investments and/or accounts with the following companies not affiliated with us:
We may also disclose personal information with non-affiliated companies and regulatory authorities as permitted by applicable law. For example, we may disclose personal information to cooperate with regulatory authorities and law enforcement agencies and as necessary to protect our rights or property. Except as described in this privacy policy, we will not use your personal information for any other purpose unless we describe how such information will be used at the time you disclose it to us or we obtain your permission to do so. Questions you may have regarding this notice CUSTOMER IDENTIFICATION PROGRAM NOTICE What types of information will I need to provide?
You may also need to show your driver’s
license or other identifying documents. U.S. Department of the Treasury, Securities and Exchange Commission, NASD, and New York Stock Exchange rules already require you to provide most of this information. These rules also may require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience and objectives, and risk tolerance. What happens if I don’t provide the information requested
or my identity can’t be verified? BUSINESS CONTINUITY PLAN
What follows is a description of how EDIF will respond to the following four types of disruptions: (1) a firm-only disruption, (2) a disruption that affects a single building, (3) a disruption that affects the entire city or business district, and (4) a disruption that affects the entire Southwest region. We have also included information about how long we expect it to take us to recover from these disruptions. To respond to a disruption that affects only EDIF, such as a computer virus, we have developed an emergency response/crisis management team. This team has, in the past, successfully guided us through disruptions that have affected our operations and has done so through the use of a crisis communications system and through procedures that address life, health, and safety issues; damage assessment; damage mitigation; personnel mobilization; and mission-critical systems. If this type of disruption takes place, we intend to restore all critical services within one day after the disruption occurs. However, in light of the various types of disruptions of this nature that could take place, it may take longer for us to resume operations in one or more of the services during any particular disruption. In the event of a disruption that affects EDIF headquarters and such as a fire in the building, our plan calls for a response involving multiple locations. We will resume critical services by moving key personnel to various locations and, to the extent necessary to our back-up facility. Certain key personnel may also work remotely by connecting to the network from a remote location. In addition to relocating key personnel to back-up faculties, we will, if necessary, transfer responsibility for certain operations and support services to our offsite offices. We intend to resume operations in all of our critical service areas within one day after a disruption of this nature occurs. It may, however, take as long as two or three days to continue doing business in one or more critical service areas depending on the availability of data a applications from our data centers. If a disruption significant enough to affect the entire city of business district, such as a terrorist attack, cuts off access to EDIF headquarters, under our plan we will resume critical services at our back-up facilities and certain EDIF offsite offices. As above, certain key employees will work remotely and certain operations and support services would be handled by other EDIF offices. We intend to resume operations in all of our critical service areas within one day after a disruption on the availability of data and applications from our data center and on the availability of key employees. In the event of a disruption that affects the entire Southwest region such as a regional power outage, we will resume critical service areas from back-up facilities and certain of EDIF offsite locations. Although EDIF intends to resume operations within one day after the disruptions occurs, one or more of our critical service areas may not be able to resume operations until the disruptions is over. In all of the situations described above, EDIF expects to resume operations within the specified time frames. However, in the event that a business disruption results in a significant loss of life at our headquarters or otherwise results in our key employees being unavailable or unable to report to their designated back-up facility, the recovery times described above may be significantly increased. Furthermore, although we expect to continue operating regardless of the type of disruption, it is impossible to anticipate every scenario. It is, therefore, possible that a significant business disruption could result in EDIF deciding that we are unable to continue doing business. In those situations, our plan provides procedures to help ensure that our customers have prompt access to their funds and securities. We are continuing to devote substantial resources to the enhancement of our business continuity plan. In addition, we may enter into agreements with other firms to perform certain clearing and services functions on our behalf in the event of a disruption, until we have the capability to resume performing those tasks. Finally, we are working towards a target point of readiness in which we will be able to resume operations within a time period that is consistent with evolving industry standards even if our key employees are unavailable. EDIF’s business continuity plan is subject to modification. We will promptly post information about updates or modifications to the plan on our website. You can also obtain updated information about the plan by requesting a written copy by mail. All requests for updated information should be sent to the following address: EDI Financial, Inc., Attn: Michael Young, 12221 Merit Drive, Suite 1020, Dallas, TX 75251. SEC ORDER ROUTING DISCLOSURE COMPLAINT NOTIFICATION |
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