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CLIENT DISCLOSURES
PRIVACY NOTICE
Bengal Partners, LLC a registered broker-dealer works to achieve the highest standards of confidentiality to safeguard the privacy of each of our clients (“Clients”). We are providing this Privacy Notice to all our Clients who obtain financial services from us, in accordance with Title V of the Gramm-Leach-Bliley Act of 1999 and its implementing regulations.
Information about Individuals Associated with a Client
The non-public personal information we may retain about any individual associated with a Client (“Information”) comes primarily from any agreements, due diligence, e-mails, or other documents that a Client may submit to us. We may also internally record Information about Client experiences with us, our affiliates, and others relating to the services or products we provide.
Our Privacy Policies
We do not disclose Information to anyone, except as permitted by law. Thus, we may share Information (a) with our affiliates, in order to bring a Client the full range of services and products available from us, and (b) with non-affiliated companies, in order to manage Client transactions with us or our affiliates or to perform other support services for a Client. Additionally, we may disclose Information if a Client gives its specific consent or instruction to us, or if the disclosure is required by law or regulations. Our privacy policy applies to current and former Clients, as well as potential Clients.
Our Internal Information Security
We limit access to Information to our staff and service providers who are involved in offering or administering the services that we offer. We maintain physical, electronic, and procedural safeguards designed to comply with federal standards to protect Information. We value our relationship with each Client and want to assure you that maintaining each Client’s privacy is important to us. If you have any question, please contact Edward McCabe – our Chief Compliance Officer – at Compliance@BengalPartners.com
BUSINESS CONTINUITY PLAN DISCLOSURE
Bengal Partners, LLC, (BPL) and its affiliates, including ICBC the clearing agent for BPL and our clients’ have created and implemented a Business Continuity Plan (BCP) to expeditiously recover and resume business operations after a Significant Business Disruption (SBD). We will respond by safeguarding our employees, property, making a financial and operational assessment, protect the firm’s books and records, and allow our clients to continue transacting business with us. Our BCP is designed to permit us to resume operations as quickly as possible, given the scope and severity of the SBD.
BPL’s BCP addresses the following: data backup and recovery; mission critical systems; financial and operational assessments; alternative communications with clients, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; and regulatory reporting. NOTE: the firm does not hold customer/client funds or securities nor does it take orders or employ any clearing facility for the purposes of settlement.
Significant Business Disruptions: The BCP takes into account two kinds of SBDs: internal and external. Internal SBDs affect only BPL’s ability to communicate and do business, such as a fire, loss of electrical power or other material event affecting our offices or building. External SBDs prevent the operation of the securities markets or a number of firms, such as a terrorist attack, a natural disaster, or another event that causes wide-scale disruption in essential services.
Internal SBDs: In the event of a disruption in BPL’s business operations due to an internal SBD, BPL will attempt to continue to conduct business as usual by utilizing alternative communication methods (if available), such as the Internet, cell phones, etc., or by moving its operations to an alternative location. If personnel or operations must be moved to an alternate location, BPL anticipates that it will resume regular operations within 24 hours.
External SBDs: In the event of a disruption in BPL’s business operations due to an external SBD, we will attempt to continue to conduct business as usual by moving our operations to an alternative location outside the affected area, if possible, or by providing clients with alternative communication arrangements, as indicated below, to conduct business. BPL will attempt to resume business within 24-48 hours and to keep its customers informed regarding relevant events to the best of its ability based on the circumstances.
In all cases, BPL will resume normal business operations as soon as it is able to do so, based on the type and the extent of the SBD. If the SBD is so severe that it prevents us from remaining in business, we will assure our clients’ prompt access to our records.
Communications during an SBD: If, during an SBD, you are unable to reach us at our main number (203-323-9838), please try to contact or JCK@BengalPartners.com or our Chief Compliance Officer, Edward McCabe, at Compliance@BengalPartners.com or emcabe@arc-sysllc.com. If you continue to be unable to reach us, contact FINRA’s Boston District office at 617-532-3400 for more information on our status and additional instructions:
General Contact information: Any questions regarding BPL’s BCP should be addressed to Edward McCabe, Chief Compliance Officer, at Compliance@BengalPartners.com
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