Identity Theft Prevention Policy

Identity Theft Prevention Policy

Red Flags Rule — 16 C.F.R. Part 681
Effective Date: April 10, 2026

TwelveFold Data Group LLC has adopted this Identity Theft Prevention Policy in accordance with the Federal Trade Commission’s Red Flags Rule to detect, prevent, and mitigate identity theft in connection with all covered accounts.

Purpose

The purpose of this policy is to establish a program for identifying, detecting, and responding to patterns, practices, or specific activities that indicate the possible existence of identity theft in connection with the opening of a covered account or an existing covered account.

Red Flags We Monitor

TwelveFold Data Group LLC monitors for the following warning signs of identity theft:

Alerts and Notifications

Fraud alerts, active duty alerts, or credit freezes appearing on a consumer report. Notifications from consumer reporting agencies indicating possible fraud or identity theft.

Suspicious Documents

Identification documents that appear altered, forged, or inconsistent. Documents where the photograph does not match the person presenting them. Identification bearing information inconsistent with other submitted documents.

Suspicious Personal Identifying Information

An address that does not match records on file. A Social Security Number associated with a deceased person. An address that is a mail drop, prison, or other non-residential facility. A phone number associated with a pager or answering service only. Multiple individuals sharing the same identifying information.

Suspicious Account Activity

Unusual payment patterns inconsistent with the established account history. Requests to change contact information shortly after account opening. Multiple accounts opened with similar identifying information from one source. Notices from consumers, law enforcement, or government agencies indicating possible identity theft.

Response Procedures

Upon detection of a Red Flag our staff will take one or more of the following steps depending on the severity of the indicator:

  • Request additional identifying documentation before opening or updating the account
  • Verify the information submitted with additional sources
  • Refuse to open the account if identity cannot be verified to our satisfaction
  • Notify our designated Compliance Officer immediately
  • File a Suspicious Activity Report if required under applicable law
  • Document all steps taken and findings in the client file
  • Notify the affected consumer as appropriate

Program Administration

This program is administered by our designated Compliance Officer who reviews and updates the program annually, provides staff training on Red Flag detection and response, and maintains records of all Red Flag incidents and responses.

Staff Training

All personnel involved in account opening or management receive training on this policy prior to handling any consumer accounts. Training is updated annually and following any material amendment to this policy.

Contact

TwelveFold Data Group LLC
30 N Gould St, Ste R
Sheridan, Wyoming 82801
support@twelvefolddata.com
1 (888) 874-2828