As a registered investment adviser, MPT must comply with SEC Regulation S -P (the “Privacy Rule”), which requires Registered investment Advisers to adopt policies and procedures to protect the “nonpublic personal information” of clients and consumers and to disclose to such person’s policies and procedures designed for protecting that information.
• Information provided from applications, forms and other information provided to us either verbally or in writing, and include but are not limited to your name, address, phone number, account information, social security number, assets, employment, income and debt; • Data about your accounts, transactions and parties to transactions and; health and beneficiary information (such as may pertain to planning issues); • Information from other outside sources; • Any other data that is deemed to be nonpublic personal information as defined by the SEC’s Regulation S-P.
Nonpublic personal information includes nonpublic “personally identifiable financial information” plus s any list, description or grouping of customers that is derived from nonpublic personally identifiable financial information. Such information may include personal financial and account information, information relating to services performed for or transactions entered into on behalf of clients, advice provided by the Adviser to clients, and data or analyses derived from such nonpublic personal information.
MPT values our clients’ and consumers’ trust and confidence. Privacy is an issue we take seriously. In its role as Investment Adviser, MPT routinely collects nonpublic personal information from clients and prospective clients. This information generally will include but is not limited to: We will never sell the nonpublic personal information we obtain from consumers or clients. All information provided by clients or prospective clients to the Adviser, (including the Adviser’s personnel), and information and advice furnished by the Adviser to clients, shall be treated as confidential and shall not be disclosed to unaffiliated third parties, except as directed by clients with written authorization, by application to facilitate the investment advisory services offered by the Adviser via an affiliated or unaffiliated financial services provider (such as the client’s selected manager, custodial firm or broker/dealer), or as required by any rule, regulation or law to which the Adviser and its staff may be subject.
MPT maintains client and consumer records in a controlled environment and records (electronic and otherwise) are only available to authorized persons of the Adviser who have a need to access client information in order to deliver advisory services, provide administrative support, or to respond to client requests. The Adviser has made reasonable efforts and conducts periodic tests to ensure that its electronic network is secure.
The Adviser’s position and policies relating to the protection of non-public personal information extends beyond the life of the Adviser’s Client Agreement. Client information is retained in a protected manner for the time period required by regulators (five years from the data of last use) and thereafter is safely destroyed via in-house shredding or a contracted secure shredding service.
Consumers (who are not clients) who provide information during an initial consultation or for other purposes but do not go on to become clients of the Adviser also receive privacy protection. Original information will be promptly returned in person or via the mail if the Adviser’s services are not engaged. Alternatively, if nonpublic personal information is contained in copies of documents, notes or some other media, this information will be securely filed for a period of up to one year (depending upon likelihood of engagement) before being shredded in-house or via our secure shredding service.
If, at any time, the Adviser adopts material changes to its privacy policies, the Adviser shall promptly provide each such client with a revised notice reflecting the new privacy policies. Clients and consumers are welcome to discuss questions or concerns relating to the Adviser’s privacy policy with Tyler Hansen, the Chief Compliance Officer of MPT.
Sharing Data with Affiliated Entities and Opportunity to Opt-Out
MPT may share nonpublic personal consumer and client information with its affiliated entities (those listed in Item 10 of this Brochure) so information about their services can be shared with you. We may begin sharing information as soon as 30 days after you have received MPT’s privacy policy disclosure but sharing will cease when you advise us of your decision to opt out of the sharing of data or when the client relationship with MPT is terminated.
Clients and consumers are welcome to opt out of this information sharing at any time by contacting My Prosper Team via email at support@myprosperteam.com, by writing to us at 3130 W Maple Loop Drive, Suite 203 Lehi, UT 84043, or by contacting the Chief Compliance Officer at (801) 889 - 1341.
