Investment advisers are required by law to inform their clients of their policies regarding privacy of client information. We are bound by professional standards of confidentiality that are even more stringent than those required by law. Federal law gives the customer the right to limit some but not all sharing of personal information. It also requires us to tell you how we collect, share, and protect your personal information.

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    PUBLIC PERSONAL INFORMATION

We collect public information from you through our client engagement process, including your phone number.   With your consent we will send to you text messages from time to time.  If you are a new customer we may begin sharing your information on the day you sign our agreement. When you are no longer our customer, we may continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing. 

 

TYPES OF NONPUBLIC PERSONAL INFORMATION (NPI) WE COLLECT

We collect nonpublic personal information about you that is either provided to us by you or obtained by us with your authorization. This can include but is not limited to your Social Security Number, Date of Birth, Banking Information, Financial Account Numbers and/or Balances, Sources of Income, and Credit Card Numbers or Information. When you are no longer our customer, we may continue to share your information only as described in this notice. 

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PARTIES TO WHOM WE DISCLOSE INFORMATION 

All Investment Advisers may need to share personal information to run their everyday business. In the section below, we list the reasons that we may share your personal information: 

➢    For everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus;
➢    For our marketing – to offer our products and services to you;
➢    For joint marketing with other financial companies;
➢    For our affiliates’ everyday business purposes –information about your transactions and experiences and information about your creditworthiness; or
➢    For non-affiliates to market to you.

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PROTECTING CONFIDENTIALITY OF CURRENT AND FORMER CLIENT’S INFORMATION 

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law, including computer safeguards and secured files and building. 

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FEDERAL AND STATE LAW SHARING ALLOWS YOU TO LIMIT SHARING – OPTING OUT 

Federal law allows you the right to limit the sharing of your NPI by “opting-out” of the following: sharing for non-affiliates’ everyday business purposes – information about your creditworthiness; or sharing with affiliates or non-affiliates who use your information to market to you. State laws and individual companies may give you additional rights to limit sharing. Please notify us immediately if you choose to opt out of these types of sharing. 

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SMS MESSAGING SERVICES

 

Overview of SMS Program

By subscribing to our SMS program you consent to receive SMS messages at the phone number provided. We use SMS to respond to SMS messages received from you, and to provide to you information on the status of certain transactions. Our custodian may use an SMS message to notify you of a transaction requiring electronic authorization. This will be a DocuSign document and require your identity to be validated prior to your ability to access the document. You may choose not to participate in this service.

 

Types of Information we collect

We collect financial account opening, employment status and personal family information. This includes your name, address, email and phone number(s). It also includes relevant non-public financial information such as Social Security number, Date of birth, bank and brokerage account information.

 

Method of data collection

We use physical forms appropriate to financial accounts that are provided on request to collect this information. Occasionally we may use an electronic form (not online) for this purpose again which will be only provided on your request.

 

How we use your personal data

The account opening information is provided to the custodian who will hold and transact your assets. They are required to maintain confidentiality of this information and are not authorized to provide it to third parties. We use the information collected to provide to you financial advice and service your accounts held at the custodian.

 

​Storage, Maintenance and Protection of Personal Information

We store and maintain your personal information in secure databases protected by industry-standard security measures. We take appropriate steps to protect your personal data against unauthorized access, disclosure, alteration, or destruction.

 

Sharing Personal Data with Third Parties

We do not share your mobile information with third parties or affiliates for marketing or promotional purposes. Additionally, all the categories of personal data mentioned above exclude text messaging originator opt-in data and consent. This information will not be shared with any third parties under any circumstances. However, we may share your data with trusted service providers who assist us in operating our SMS program, provided they agree to keep your data confidential and use it solely for the purpose of providing services on our behalf.

 

Managing Your Personal Information

You have the right to access, correct, verify, or remove your personal information at any time. To manage your information, please contact us at Prometheus. Opt-Out Option: If you wish to opt-out of receiving SMS messages, you may do so at any time by replying "STOP" to any of our messages or by contacting us directly at Prometheus. Opting out will not affect your other interactions with our services.