PROSPERO WEALTH PRIVACY POLICY
Prospero Wealth, LLC (“Prospero Wealth”) recognizes that our relationships with current and prospective clients are based on integrity and trust. We work hard to maintain your privacy and to preserve the private nature of our relationship with you and place the highest value on the information you share with us.
Prospero Wealth will not disclose your personal information to anyone unless it is required by law or at your direction. We will not sell your personal information.
We want our clients to understand what information we collect, how we use it, and how we protect your personal information.
Why We Collect Your Information
We gather information about you so that we can:
Help design and implement the investment and financial planning related services we provide you; and
Comply with the Federal and State laws and regulations that govern us.
What Information We Collect and Maintain
We may collect the following types of “nonpublic personal information” (“NPI”) about you:
Information from our initial meeting or subsequent consultations about your identity, such as your name, address, social security number, date of birth, and financial information;
Information that we generate to service your financial needs; and
Information that we may receive from third parties in connection with the services we provide you.
Recordings and transcriptions of client meetings are utilized (via Artificial Intelligence Note-takers) for the purpose of note-taking and follow up task management. These tools improve the quality of advisor notes and allow for more effective meetings. It is our policy that all recordings and transcriptions used for meeting notes are deleted within 30 days.
What Information We Disclose
We are permitted by law to disclose nonpublic information about you to unaffiliated third parties in certain circumstances. Prospero Wealth may disclose a client’s NPI:
to individuals and/or entities not affiliated with Prospero Wealth, including, but not limited to third-parties that assist in the supervision or management of your account(s) (i.e., sub-advisers, account custodian, record keeper, attorney, etc.);
to service providers contracted by us in order for us to perform the duties in furtherance of the client’s engagement with Prospero Wealth (i.e. client management systems, archiving technology vendors, cloud service providers, etc.);
to your authorized representative or power of attorney;
when we receive your prior consent;
in connection with a proposed or actual sale, merger, or transfer of all or a portion of our business; and
as otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations.
In the event that Prospero Wealth has a change to its client privacy policy that would allow it to disclose non-public information not covered under applicable law, Prospero Wealth will allow its clients the opportunity to opt-out of such disclosure.
How We Protect Your Personal Information
Privacy has always been important to Prospero Wealth. We restrict and limit access to client information only to those who need to carry out their business functions. We safeguard client information by preventing its unauthorized access, disclosure, or use. We maintain physical, electronic, and procedural safeguards to protect your confidential personal information. Arrangements with companies or independent contractors not affiliated with Prospero Wealth will be subject to confidentiality agreements.
Use of AI
We maintain a comprehensive AI Policy, along with a set of guiding principles, on our website at prosperowealth.com/ai-policy. The short version of our policy is that we maintain a client data classification, a register of approved use cases, and a register of approved AI systems. The AI committee meets at least twice per year to review and assess new proposed additions to our policy.
We scale the depth of our reviews and approval process relative to the sensitivity of the data that the AI system can access or utilize.
Former Clients
Even if we cease to provide you with financial services, our Privacy Policy will continue to apply to you, and we will continue to treat your nonpublic information with strict confidentiality. We maintain all records regarding all former clients for the retention period required by law.
Contact Us
Clients are encouraged to discuss any questions regarding privacy policies and procedures directly with Eric Franklin, Chief Compliance Officer of Prospero Wealth. Please contact Eric at eric@prosperowealth.com or 206-737-7345.
