ETL Group LLC

Information Security Policy

Effective October 29, 2026 · Reviewed at least once a year and after any significant change or incident.

1. Purpose and scope

This policy describes how ETL Group LLC ("ETL Group", "we") protects the information and systems it uses to run its transportation businesses and internal software. It covers all company systems, cloud services, devices and people with access to them, including the internal tools that connect to our own financial accounts through Plaid.

2. Responsibility

Information security is owned by Amon Safarov, Owner (amon@etlgroupllc.com). The owner approves this policy, decides on access, and is the contact for security questions and incident reports.

3. Risk management

We identify risks to our data and systems, decide how to reduce them, and monitor for problems. Automated checks review uptime, email authentication (DMARC/SPF/DKIM), user accounts and application errors daily, and findings are reported to the owner. Risks are reassessed when we add a new system, vendor or data source.

4. Access control

5. Authentication

Multi-factor authentication (MFA) is required on all systems that hold company or financial data, including email and identity (Google Workspace), banking, the password manager and cloud consoles. Credentials are stored in a password manager or in access-restricted secret stores, never in source code or chat.

6. Encryption

7. Vulnerability and patch management

We follow security advisories and news for the software and services we use. When a significant vulnerability is disclosed, we assess whether we are affected and patch, mitigate or reconfigure promptly. Operating systems, dependencies and services are kept on supported, updated versions, and application errors are monitored centrally.

8. Data handling and retention

We collect only the data we need. Financial data obtained through Plaid is limited to ETL Group's own accounts and is used only for internal analysis. It is not sold or shared with third parties. A bank connection can be removed at any time, which revokes access and deletes the stored access token. See the Privacy Policy for details.

9. Vendors

We use established providers (for example Google Workspace, Amazon Web Services and Plaid) and give each only the access it needs.

10. Incident response

Suspected security incidents are reported to amon@etlgroupllc.com immediately. We contain the issue (for example by revoking sessions, resetting credentials or disconnecting integrations), investigate, fix the cause and notify affected parties and partners, including Plaid, as required.