BUSINESS CONTINUITY PLAN DISCLOSURE
Next Titan Capital, (“Next Titan” or the “Firm”) is committed to safeguarding the interests of our clients and customers in the event of an emergency or significant business disruption. This Business Continuity Plan Disclosure (the “BCP”) summarizes Next Titan’s effort to mitigate risks inherent with unforeseen business interruptions. The Firm’s comprehensive business continuity strategy is designed to enable us to meet our existing obligations to our clients and customers even in such an event. This BCP is intended to comply with the rules promulgated by the Financial Industry Regulatory Authority (“FINRA”).
Next Titan Capital maintains one primary and one alternate facility to house the backbone of our operations and information technology. These two facilities are separated by proximity sufficient to diminish risks posed by local disruptions. This separation is a key element of the Firm’s overall business continuity strategy, allowing us to plan for events at each location individually, since no single event is likely to effect more than one location simultaneously. The benefit of having only one site in each location means our response to an event will be the same whether the event is localized within the Firm itself or city- wide.
COMMUNICATION WITH OUR EMPLOYEES IN THE EVENT OF A DISRUPTION
The safety and well-being of our employees is a vital concern. In the event of an emergency or significant business disruption, the Firm will communicate with its employees in several different ways. We use a combination of telephone, facsimile, e-mail, and mobile phone. General information such as office closures and operating hours will sent via e-mail to registered and non-registered employees on the Firm’s contact lists.
PROTECTION OF PRIMARY FACILITIES
Protecting the infrastructure of our primary facilities is a high priority because it will allow the firm to continue operations in the event of many disaster situations, by permitting our employees to have access to and use of our facilities during that situation.
The Firm’s comprehensive business continuity strategy is designed to enable us to meet our existing obligations to our clients and customers even in the event of an emergency or significant business disruption; however it is not infallible. The plan is designed to work in many different emergency situations; but these events are, by their nature, unpredictable and it is impossible to anticipate every scenario that could cause a business disruption. Furthermore, although we are confident in our own preparedness, Next Titan has no control over the various entities that we must rely upon in the event of an emergency. Our business continuity plans are tested periodically to ensure readiness; yet such tests may not be able to replicate the actual conditions we experience in a real emergency. This BCP is subject to change without notice. In the event that this BCP is modified, customers may obtain an updated hard copy BCP upon request and will be provided annually thereafter. The information contained in this disclosure is provided by Next Titan for informational purposes only.
Nothing contained herein shall be construed to amend, supplement or otherwise modify any of the terms and conditions set forth in any client agreement between you and Next Titan.
Next Titan Capital is a Registered Broker Dealer (Member of FINRA, SIPC)
Next Titan Capital is committed to maintaining the trust and confidence of our clients. We want you to understand how we protect your privacy when we collect and use your nonpublic personal information (“personal information”) in the course of business, as well as the measures we take to safeguard your personal information. Keeping personal information secure and private is a priority at Next Titan Capital
HOW WE COLLECT YOUR PERSONAL INFORMATION
While providing service to you, we collect personal information from the following sources:
Client Intake forms and other standard forms related to your accounts. Examples of information collected may include your name, address, Social Security number, assets, types and amounts of investments, transactions and income.
Consumer reporting agencies, including information concerning your credit worthiness and credit history.
Information obtained from third parties when verifying applications or other forms. This may be obtained from your current or past employers or from other institutions with which you conduct financial transactions.
Keeping your information secure is one of our most important responsibilities. We restrict access to your personal information to those employees and agents who assist us in providing products or services to you. We maintain physical, electronic and procedural safeguards that comply with applicable law to protect your personal information. We train our employees in the proper handling of personal information. When we use other companies to help provide our services to you, we require them to protect the confidentiality of personal information they receive.
USE OF “COOKIES”
DISCLOSING PERSONAL INFORMATION TO NON-AFFILIATED THIRD PARTIES
We do not sell, share or disclose your personal information to non-affiliated third-party marketing companies, except personal information we share with other financial institutions pursuant to joint marketing agreements we enter into with them.
We may disclose all of the information we collect, as described above in the section captioned “How We Collect Your Personal Information,” to companies that perform marketing or other services on our behalf and to other financial institutions with which we have joint marketing agreements. All of these companies are contractually obligated to keep the information that we provide confidential and use the information only to provide the services as allowed by applicable law or regulation. They are not permitted to share or use the information for any other purpose. We may also disclose all of the information we collect to our affiliates, as described above in the section captioned “How We Collect Your Personal Information.” To the extent that state laws grant you greater in with our sharing of your will comply with those laws.
We may also disclose your personal information as permitted or required by law. These disclosures may include, for example, information to process transactions on your behalf, to conduct our operations, to follow your instructions as you authorize, or to protect the security of your financial records.
DISCLOSING PERSONAL INFORMATION TO AFFILIATES
We do not share your personal information with other organizations for marketing purposes.
IF YOUR RELATIONSHIP WITH US ENDS
If your relationship with us ends, we will continue to treat personal information in accordance with this Privacy Notice. That means that we may continue to share your personal information with our lending partners and affiliates as described above or permitted by law. However, if you notify us of your election not to have us share your personal information with others before or after your relationship with us ends, we will honor that request.
We reserve the right to amend (that is, to add to, delete from, or change) the terms of this Privacy Notice from time to time. Our Privacy Notice, as in effect from time to time, is continually posted on our website. By electing to become one of our customers or by receiving our products and related services, you agree to receive copies of our Privacy Notice and any amendments to it from our website, unless you notify us otherwise in writing at the address provided below.
VIEW AND CHANGE YOUR PERSONAL INFORMATION
You can review your personal information and make any needed corrections to it by contacting us in writing at the address listed below.
CONTACT AND RIGHT TO ACCESS AND CORRECT INFORMATION
You may write to us at the address listed below with any questions you may have about your personal information. You may see and copy the personal information that we have about you in person. If you prefer, we will copy and send it to you. If you think the personal information that we have in our files is incomplete or incorrect, you may request that we complete or correct the disputed personal information. We will review your request. We will either or explain why we did not do so. If we do not make the change, you may file a written statement of dispute with us. We will include the written dispute in future disclosures of that personal information. We will send the written dispute to anyone you ask who received your personal information from us in the past two years. To exercise these rights, please send us a written request. Please include your name, address, account number, daytime phone number, and the personal information that you would like access to or that you believe needs correction. We may charge a small fee to collect and send the personal information to you. To protect your personal information, we may ask you to verify your identity and to provide other details to respond to your request.
Our mailing address for purposes of this Privacy Notice is:
Next Titan Capital 1023 Walnut Street
Boulder, CO 80302
Attn: Chief Operating Officer
Questions related to the protection of your Social Security number or your other personally identifiable information may be sent to this address as well.
Next Titan Capital is a Registered Broker Dealer (Member of FINRA and SIPC)