Pragma shall take appropriate precautions, and collect only the minimum amount of information on a person in order to provide our software and services, or follow-up on inquires through our website.
The Policy covers all customers’ and prospective customers’ personal information, including but not limited to names, phone numbers, email addresses, financial information, intellectual property and trade secrets. Pragma will not sell, lease or distribute this data to any third parties unless we are required to by a regulator or court order. For the avoidance of doubt, customer trading data must be maintained by the Company as required by its regulators and its data retention policies, and is governed by the confidentiality clauses in customer agreements. Therefore, customer trading data is not covered by the Policy. In addition, the Policy does not cover emails that are archived for regulatory purposes.
Pragma shall protect the confidentiality of its customers’ and prospective customers’ information that it receives and it shall use commercially reasonable efforts to comply with any requests it receives from its customers to return or destroy such personal information, subject to any legal and regulatory restrictions. From time to time we will make changes to our Policy.
Pragma has developed a Business Continuity Plan on how it will respond to events that significantly disrupt business activities. Since the timing and impact of a disaster or disruption is unpredictable, we must be flexible in responding to 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 212.777.0052 you should call our alternative numbers 917.678.1626, 516.587.7207.
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 operational 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; mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical suppliers, contractors, and banks.
While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, if our core technology infrastructure is intact, we generally aim to be able to restore our own operations and be able to resume services within 24 hours of a severe disruption. Our algorithmic trading services could be delayed or unavailable during this period.
Varying Disruptions – Significant business disruptions can vary in 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 entire region. Within each of these areas, the severity of the disruption can also vary from minimal to severe.
We take several precautions to allow us to respond flexibly to range of disruptions. These precautions include running our core technology out of a high availability commercial datacenter that will be resilient to power interruption, maintaining a secondary datacenter, making plans for employees to communicate with each other, access our business records, and support our services from remote locations in the event we can’t work from our offices, and backing up important records in a geographically separate area from our primary locations.
In a disruption that prevents our staff from reaching or working from our offices, we will transfer operations to work in a distributed fashion, and expect to recover and resume business within 24 hours. In a disruption affecting our region that prevents this, we will work to transfer critical staff to a site outside of the affected area, and recover and attempt to resume business as soon as possible. In either situation, we plan to notify you how to contact us, either through direct calls to our customers, or through our web site,
For more information – If you have questions about our business continuity plan, you can contact us at 212.897.0940.