Privacy Policy

PRIVACY POLICY/REGULATION S-P

Background

As a registered investment adviser, Prism must comply with SEC Regulation S- P and other applicable regulations, which requires registered advisers to adopt policies and procedures to protect the "non-public personal information" of natural person clients, and to disclose to such clients the policies and procedures for protecting that information. Additionally, Prism complies with new SEC Regulation S- AM, to the extent that the firm has affiliated entities with which it may share and use client information received from affiliates.

Prism views protecting its clients’ private information as a top priority and, pursuant to the requirements of the Gramm-Leach-Bliley Act (the “GLBA”), Prism has instituted the following policies and procedures to ensure that client information is kept private and secure.

This policy serves as formal documentation of Prism’s ongoing commitment to the privacy of its clients. All representatives will be expected to read, understand, and abide by this policy and to follow all related procedures to uphold the standards of privacy as set forth by Prism. This policy and the related procedures contained herein are designed to comply with applicable privacy laws, including the GLBA, and to protect the non-public personal information of Prism’s clients.

In the event of new privacy-related laws or regulations affecting the information practices of Prism, this Privacy Policy will be revised as necessary, and any changes will be disseminated and explained to all personnel.

Scope of Policy

This Privacy Policy covers the practices of Prism and applies to all non-public personally identifiable information of our current and former clients.

Overview of the Guidelines for Protecting Client Information

The overall securities standards that Prism upholds are to:

Ensure the security and confidentiality of client records and information.
Protect against any anticipated threats or hazards to the security or integrity of client records and information; and
Protect against unauthorized access to, or use of, client records or information that could result in substantial harm or inconvenience to any client.

Representative Responsibility

Each representative has a duty to protect the non-public personal information of clients collected by Prism.
No representative is authorized to disclose or use the non-public information of clients on behalf of Prism.
Each representative has a duty to ensure that non-public personal information of Prism’s clients is shared only with representatives and others in a way that is consistent with Prism’s Privacy Policy.
Each representative has a duty to ensure that access to non-public personal information of Prism’s clients is limited as provided in the Privacy Policy provided.
No representative is authorized to sell on behalf of Prism or otherwise, non-public information of Prism’s clients.
Representatives with questions concerning the collection and sharing of, or access to, non-public personal information of Prism’s clients must look to Prism’s CCO for guidance.
Violations of these policies and procedures will be addressed in a manner consistent with other Prism disciplinary guidelines.

Information Practices

Prism collects non-public personal information about clients from various sources.

These sources and examples of the types of information collected include:

Product and service applications or other forms, such as client surveys, agreements, etc. These often include the name, address, age, social security number or taxpayer ID number, assets, and income.
Transactions including the account balance, and types of transactions and investments.
Other third-party sources.

Disclosure of Information to Non-Affiliated Third Parties – “Do Not Share” Policy

Prism has a “do not share” Privacy Policy. It does not disclose any non-public personal information about clients or former clients to non-affiliated third parties, except for the GLBA privacy exceptions. Under no circumstances does Prism share credit-related information, such as income, total wealth, or other credit header information with these non-affiliated third parties.

Types of Permitted Disclosures – The Exceptions

Prism is permitted under certain circumstances to provide information to non-affiliated third parties to perform services on Prism’s behalf. In addition, there are several “ordinary course” exceptions which allow Prism to disclose information that is necessary to effect, administer, or enforce a transaction that a client has requested or authorized. A more detailed description of these exceptions is set forth below.

Service Providers

From time-to-time, Prism may have relationships with non-affiliated third parties that require it to share client information for the third party to carry out services for Prism. These non-affiliated third parties would typically represent situations where Prism or its representatives offer products or services jointly with another financial institution, thereby requiring Prism to disclose client information to that third party.

Every non-affiliated third party that falls under this exception is required to enter into an agreement that will include the confidentiality provisions required by Regulation S-P, which ensure that each such non-affiliated third party uses and re-discloses client non-public personal information only for the purpose(s) for which it was originally disclosed.

Processing and Servicing Transactions

Prism may also share information when it is necessary to effect, administer, or enforce a transaction for our clients or pursuant to written client requests. In this context, “necessary to effect, administer, or enforce a transaction” means that the disclosure is required, or is a usual, appropriate, or acceptable method:

To carry out the transaction or the product or service business of which the transaction is a part, record, service, or maintain the client’s account in the ordinary course of providing the financial service or financial product.
To administer or service benefits or claims relating to the transaction or the product or service of which it is a part.
To provide a confirmation, statement, or other record of the transaction, or information on the status or value of the financial service or financial product to the client or the client’s agent or broker; or
To accrue or recognize incentives or bonuses associated with the transaction that is provided by Prism or any other party.

Sharing as Permitted or Required by Law

Prism may disclose information to non-affiliated third parties as required or allowed by law. This may include, for example, disclosures in connection with a subpoena or similar legal process, a fraud investigation, recording of deeds of trust and mortgages in public records, an audit, or examination, or the sale of an account to another financial institution.

Prism has taken the appropriate steps to ensure that it is sharing client data only within the exceptions noted above. Prism has achieved this by understanding how Prism shares data with its clients, their agents, service providers, parties related to transactions in the ordinary course or joint marketers.

Provision of Opt Out

As discussed above, Prism currently operates under a “do not share” policy and therefore does not need to provide the right for its clients to opt out of sharing with non-affiliated third parties. If our information sharing practices change in the future, we will implement opt-out policies and procedures and make them appropriate.

disclosures to our clients.

Safeguarding of Client Records and Information

Prism has implemented internal controls and procedures designed to maintain accurate records concerning clients’ personal information. Prism’s clients have the right to contact Prism if they believe that Prism records contain inaccurate, incomplete, or stale information about them. Prism will respond in a timely manner to requests to

correct information. To protect this information, Prism maintains appropriate security measures for its computer and information systems, including the use of passwords and firewalls.

Additionally, Prism will use shredding machines, locks, and other appropriate physical security measures to safeguard client information stored in paper format.

Security Standards

Prism maintains physical, electronic, and procedural safeguards to protect the integrity and confidentiality of client information. Internally, Prism limits access to clients’ non-public personal information to those representatives who need to know such information to provide products and services to clients.

Privacy Notice

Prism has developed a Privacy Notice to be delivered to clients initially and on an annual basis. The notice discloses Prism’s information collection and sharing practices and other required information and has been formatted and drafted to be clear and conspicuous. The notice will be revised as necessary any time information practices change.

Privacy Notice Delivery

Initial Privacy Notice - As regulations require, all new clients receive an initial Privacy Notice at the time when the client relationship is established, for example on execution of the agreement for services. Annual Privacy Notice - The GLBA regulations require that disclosure of the Privacy Policy be made on an annual basis. Prism will deliver its annual Privacy Notice in conjunction with the annual offer of its Form ADV Part 2.

Revised Privacy Notice

As per regulation S-P, Prism will amend its Privacy Policy and distribute a revised disclosure to clients if there is a change in Prism’s collection, sharing, or securities practices.

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