The Firm considers the protection of sensitive information to be a sound business practice and a foundation of customer trust. We protect sensitive information that we collect from and about customers by maintaining physical, electronic, and procedural safeguards that meet applicable legal and regulatory requirements. The Firm uses firewall and router protocols to control the flow of information, which should adequately protect confidential information. The Firm utilizes the services of a third-party technology expert to control the remote access of Firm employees from their personal computers to information stored at the office or with other third-party vendors. If the Firm suspects that its system is subject to vulnerability, such as due to an alert from the anti-virus protection program, the Firm shall engage a third-party technology expert to review the system and ask for a review report or certification. When disposing of customer information that is not or is no longer subject to regulatory records retention requirements, the Firm shall use necessary precautions such as shredding, if the records are in paper, and deleting the electronic version of customer information only using the computers in the office with a secure connect.
The Firm only conducts business with institutional customers and therefore is not subject to the requirements of Reg S-P or Reg S-ID. However, the Firm still recognizes the sensitivity of the information it retains with respect to its institutional customers and safeguards such information to the fullest extent possible. Non-public customer information is only shared with service providers pursuant to an agreement approved by the Firm. Information about current or former customers is shared only with service providers in connection with servicing or processing a financial product or service requested or authorized by the customer. Access to customer accounts and customer information is restricted to associated persons of the Firm who need to know that information in order to provide products or services to that customer.
Because the Firm does not have individual customers, the Firm does not share non-public personal customer information with third parties.
The Firm’s personnel shall be given instructions on handling and protecting sensitive customer information as part of their initial hiring, as part of the Firm’s continuing education program, or as otherwise deemed necessary by the Firm.
Luminex Trading & Analytics LLC