CM Securities Disclaimer
CM Securities (“CMS”) is committed to safeguarding the non-public personal information that you provide to us. This Privacy Policy describes how we handle and protect non-public personal information we collect about individuals such as you, who apply for or receive our products and services, or have previously.
Why And How We Collect Personal Information
When you apply for or maintain an account with CMS, we collect non-public personal information about you for business purposes, such as evaluating your financial needs, processing your requests and transactions, informing you about products and services that may be of interest to you, and providing customer service. The information we collect about you includes: information you provide to us on applications and other account forms, such as your name, address, date of birth, social security number, occupation, assets, and income; information about your transactions with us and our affiliates; information you provide to us to verify your identity, such as government-issued identification, that we receive from other entities not affiliated with CMS.
How We Protect Information
We limit access to your non-public personal information to those employees who need to know in order to conduct our business, service your account, and help you achieve your financial objectives. Our employees are required to maintain and protect the confidentiality of your non-public personal information and must follow established procedures at all times. We maintain physical, electronic, and procedural safeguards to protect your non-public personal information. We do not rent or sell your name or non-public personal information to anyone for any reason. In addition, it should be noted that even if you decide to close your account(s) or become an inactive customer, we will adhere to the privacy policies and practices as described in this notice.
Sharing Information With Our Affiliates
CMS may disclose the information that we collect about you to our affiliates who offer financial products or services.
Disclosure To Non-Affiliated Third Parties
In order to support the financial products and services that we provide to you, we may share the information described above with third-party service providers not directly affiliated with us, including:
Companies under contract to perform services for us or on our behalf, such as vendors that prepare and mail statements and transaction confirmations or provide data processing, computer software maintenance and development, transaction processing and marketing services.
These companies acting on our behalf are required to keep your non-public personal information confidential.
In addition, we may disclose information to cooperate with regulatory authorities and law enforcement agencies to comply with subpoenas or either official requests, and as necessary to protect our rights or property.
Accessing And Revisiting Your Personal Information
We endeavor to keep our customer files complete and accurate. We will give you reasonable access to the information we have about you. Most of this information is contained in account statements that you receive from us and applications that you submit for our products and services. We encourage you to review this information and notify us if you believe any information should be corrected or updated. If you have a question or concern about your non-public personal information or this privacy notice, please contact your CMS representative.
We will provide our privacy policy to you annually as long as you maintain an account with us. This policy may be modified from time to time to comply with applicable laws or to conform to our current business practices. If we modify this policy, you will be notified of any changes.
Business Continuity Disclosure Policy
CM Securities, LLC (“Firm”) is a FINRA registered broker/dealer providing brokerage services to its customers. Accordingly, the Firm is furnishing this document to all clients to provide information about its efforts to ensure that the Firm’s securities operations will not be significantly impacted as a result of an emergency or significant business disruption.
Securities industry regulations require each member firm to create and maintain a Business Continuity Plan reasonably designed to meet its obligations to its clients or other counterparties. In accordance with these requirements, the Firm has designed a Business Continuity Plan to address possible scenarios in efforts to minimize the impact to our clients.
In keeping with the regulatory requirements, the business continuity plan for the Firm is designed to address key areas of concern including, but not limited to, the following:
• Data back-up and recovery;
• All mission critical systems;
• Financial and operational assessments;
• Alternate means of communication between the Firm and its employees;
• Alternate means of communication between the Firm and its customers;
• Alternate physical locations of employees;
• Critical business constituent, bank, and counter-party impact;
• Regulatory reporting;
• Communications with regulators; and
• How the Firm will ensure that customers have access to their funds and securities in the event that the Firm determines it is unable to continue its business.
Since events creating business disruptions may vary in nature and scope, the Firm has anticipated scenarios in which the following are affected:
• A disruption to the Firm’s primary or main office location;
• A disruption to a single building where the Firm’s main office is located;
• A disruption to the business district or city where the Firm’s primary systems are located;
• A disruption to the region where the Firm’s primary systems are located.
Regardless of the scope of potential disruption, the Firm intends to continue to provide the utmost service to its clients.
A Disruption to the Firm and/or Single Building
In the event of a significant business disruption to the Firm and/or the building in which the Firm is located, the Firm has duplicative systems that will be operated from a separate back-up (“alternate”) site. This disruption may be caused by physical damage, technological problems, or an inability for personnel to arrive at the office. As such, the Firm will transfer operations to its designated alternate site located in another building within close proximity to the Firm’s main operations. The alternate site will be used to restore internal operations, as well as electronic access and communications, as soon as key employees are relocated to the site. In this process, clients may experience a minor delay in reaching the Firm due to increased telephone calls, technological delays, or other minor difficulties arising from the transfer of operations. The Firm expects that any delay will be less than twelve (12) hours. Nevertheless, the unlikely failure of telephone or other ancillary communications systems could result in a delay of up to twenty-four (24) hours.
A Business-District, Citywide, or Regional Disruption
In the event that there is a significant business disruption that affects the business district or city where any of the Firm’s primary systems are located, the Firm will transfer operations to its designated backup (“alternate”) site located in a separate and distinct business district and city apart from the Firm’s main operations. The alternate site will be used to restore internal operations, electronic access, and communications as soon as key employees are relocated to the site.
In the event of a significant business disruption to the region where the Firm’s primary systems are located, the Firm intends to take advantage of any available facilities of other affiliates that may be located in other geographical regions. As such, the Firm may use an alternate location that currently operates in another region that will effectively leverage the use of technology and infrastructure to continue operations. Under this arrangement, the selected locations will be determined sufficiently capable to operate as a designated back-up facility. In this process, Clients may experience minor delays in reaching the Firm due to increased telephone calls, technological delays, or other minor difficulties arising from the transfer of operations. The Firm expects that any delay will be less than seventy-two (72) hours.
Nevertheless, there can be no assurance that service will continue without interruption in certain circumstances, such as a regional blackout, a natural disaster, or terrorist attack. However, in the unlikely event that the Firm has determined that it cannot resume operations within a reasonable amount of time, it will provide as much advance notice as possible regarding its ongoing operations.
At a minimum, the Firm’s Business Continuity Plan is reviewed and updated as necessary on an annual basis. Additionally, our primary internal and external application and service providers periodically conduct testing of their own back-up capabilities to ensure that in the event of an emergency or significant business disruption, they will be able to provide us with the critical information and applications we need to continue or promptly resume our business.
Making sure that any type of disruption does not unduly impact our clients is extremely important to us, and our business continuity plan is designed to allow us to continue to provide the quality service that all of our clients deserve and expect. |
