Business Continuity Program Notice
Alluvion Securities, LLC ("Alluvion") has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.
Contacting Us - If after a significant business disruption you cannot contact us as you usually do at 901-763-0744, you should call our alternative number at 901-604-6866. If you cannot access us through those means, you should contact our clearing firm, Southwest Securities, at 214-859-1800 / 813-908-2412 or at www.swst.com for instructions on how it may assist you in receiving prompt access to funds or securities, entering orders and processing other trade-related items or receiving security transfer instructions.
Our Business Continuity Plan - We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operation assessment, protecting our firm's books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.
Our business continuity plan addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.
Our clearing firm, Southwest Securities, backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within no more than four hours. Your orders and requests for funds and securities could be delayed during this period.
Varying Disruptions - Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region.
Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer out operations to a local site when needed and we expect to recover and resume business within one business day. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within one to two business days. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer's prompt access to their funds and securities.
For More Information - If you have questions about our business continuity planning, you may contact us at 901-763-0744.
We comply with the USA Patriot Act, Section 326. Please read this important information about opening a new account with firm.
To help the government fight the funding of terrorism and money laundering activities, federal law requires financial institutions to obtain, verify, and record information that identifies each person who opens an account.
Types of Information You Will Need to Provide:
When you open an account, Alluvion is required to collect information such as the following from you:
- Your name
- Date of birth
- Identification number:
U.S. Citizen: taxpayer identification number (Social Security number or employer identification number).
Non-U.S. Citizen: taxpayer identification number, passport number and country of issuance, alien identification card number, or government-issued identification showing nationality, residence, and a photograph of you.
You may also need to show your driver's license or other identifying documents. Alluvion may also screen your name against various databases to verify your identity. All information and documentation will be treated in a manner so as to protect your privacy.
A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, government-issued business license, a partnership agreement, or a trust agreement.
Securities and Exchange Commission, FINRA, and New York Stock Exchange rules may also require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience and investment objectives.
If Your Identity Cannot Be Verified
We thank you for your patience and hope that you will support Alluvion's efforts to deny terrorists and money launderers access to America's financial system.
In certain circumstances we may not be able to open an account or conduct any transactions for you until we have obtained and verified the necessary identification information. If we have opened an account for you, we may have to restrict trading or close it if you do not supply the necessary information or documents, or if we are unable to verify your identity.
At Southwest Securities, Inc. (Southwest), we are committed to protecting your privacy and the confidentiality of your personal and financial information. The measures we take to keep your personal information private and secure are outlined below.
Southwest Securities, Inc. has multiple affiliates, including SWS Financial Services, Inc., SWS Capital Corporation, Southwest Securities, FSB and Southwest Insurance Agency. These companies, along with Southwest Securities, Inc., are wholly owned subsidiaries of SWS Group, Inc., a financial holding company whose stock is listed on the New York Stock Exchange under the ticker symbol SWS. Since the affiliates are all part of one corporate family, they work with one another and may work together to service your financial needs. The sharing of your information among our affiliates enables us to serve you more efficiently and makes it more convenient for you to do business with us. We are permitted by law to share information with our affiliates about your account history and your experiences with us. All of our affiliates follow the same privacy policies.
How We Protect Confidentiality
Southwest uses procedural, physical and electronic system safeguards to store and secure information about you in compliance with federal standards. Our systems protect your information from unauthorized access, alteration, and destruction. Access is permitted only to those individuals within our organization who need the information to perform their job responsibilities.
When we enter into agreements with other companies to provide services to us or to make products and services available to you, we include a confidentiality clause. Under such an agreement, these companies may receive information about you, but they may only use it for the intended purpose - to benefit you.
How We Obtain Information About You
In the normal course of business, we collect, retain and use information about you to serve your financial needs, administer your account(s) and inform you of products and services that may be of interest. This data, known as non-public personal information, may be collected from several sources, including: applications and other forms you file with us (e.g., name, assets, income), records of transactions with us, our affiliates, non-affiliated third parties and others (e.g., credit report). Because we strive to provide you with the best possible service, the accuracy and completeness of your personal information is important to us. We ask that you review your information regularly to ensure that it is correct. Please contact your account representative or Southwest directly if you need to correct or update your personal information.
Sharing Information-With Whom and Why
Southwest does not sell your personal information to anyone. We restrict the types of information we share and the types of entities with whom we share it. The primary reason for sharing information about you is to increase your convenience in transacting business with us and to give you more financial service choices.
We do not disclose your personal information to non-affiliated third parties, unless one of the following exceptions applies:
We disclose personal information to service providers that assist us in processing your transactions or servicing your account(s). An example would be the company that prints and mails your account statement. We may also disclose personal information to third party service providers in an effort to improve and better market the products and services we offer.
We disclose or report personal information in limited circumstances when we believe in good faith that disclosure is required or permitted under law. For example, we would provide information in cooperation with securities regulators or law enforcement authorities, to resolve consumer disputes, or to perform credit evaluations and authenticate checks.
We do not retrieve account or personal information from visitors who browse the public (pre-logon) areas of our Web sites. Clients who have the ability to access their accounts online are required to log on with their user name and individually selected password. Your password is known solely to you, the client, and should never be shared with anyone. You may change your password as often as you wish.
When you access your account online, it is through a Secure Socket Layer-encrypted session between your browser and our servers. To ensure the highest level of security, we have installed VeriSign Global Server IDs on each server. We will continue to enhance security procedures as new technologies become available. Each time you access your account please
don't forget to log off when you are finished. This will prevent someone else from accessing your account if you leave your computer and your session hasn't automatically shut down.
Southwest employees use information about you to respond to your needs and to provide you with information about specific products in which you may have an interest. We instruct our employees to use strict standards of care in handling the personal, confidential information of customers and remind them on a regular basis of their obligations with regard to the confidentiality of customer information.
Option to Opt Out and Change Notices
If for any reason at any time in the future, we find it necessary to disclose any of your personal information in a way that is inconsistent with this policy, we will give you advance notice of the proposed change and the opportunity to opt out of such disclosure.
For your reference, this policy has been posted to our Web site at www.swst.com. If you have questions or concerns, please contact us via email at firstname.lastname@example.org.