Privacy Policy

Last updated: 3/26/24

C2P CAPITAL ADVISORY GROUP, LLC D.B.A. PROSPERITY CAPITAL ADVISORS (PCA)AFFILIATED SUBSIDIARY OF C2P ENTERPRISES, LLC PRIVACY NOTICE REGARDING CLIENT PRIVACY AS REQUIRED BY REGULATION S-P & REGULATION S-AM.

Maintaining the trust and confidence of our clients is a high priority. That is why PCA wants you to understand how we protect your privacy when we collect and use information about you and your accounts, and the steps that we take to safeguard that information. This notice is provided to you on behalf of C2P Capital Advisory Group, LLC d.b.a. Prosperity Capital Advisors.

In connection with providing investment products, financial advice, or other services, PCA obtains nonpublic personal information about you, including:

• Information we receive from you on account applications, including but not limited to your address, your email address, date of birth, Social Security Number, occupation, financial goals, assets and income;
• Information about your transactions with us, our affiliates, or others;
• Information received from credit or service bureaus or other third parties, including but not limited to your credit history and/or employment status.
• Information about your computer and about your visits to and use of our website and our third-party vendor websites (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation path)

PCA may only disclose information that we collect in accordance with this policy and to the extent permitted by law. C2P Capital Advisory Group, LLC d.b.a. Prosperity Capital Advisors does not sell customer lists and will not sell your name to telemarketers.

PCA will not disclose information regarding you or your account with us, except under the following circumstances:

• To your authorized Registered Representative or Investment Adviser Representative and their manager;
• To our parent companies or their affiliates, to the extent permitted by law;
• To entities that perform services for us or function on our behalf, including financial service providers, including but not limited to a clearing broker-dealer, investment company, or insurance company;
• To consumer reporting agencies,
• To third parties who perform services or marketing on our behalf;
• To your attorney, trustee or anyone else who represents you in a fiduciary capacity;
• To our attorneys, accountants or auditors; and
• To government entities or other third parties in response to subpoenas or other legal process as required by law or to comply with regulatory inquiries.

Google Analytics is a web analysis service provided by Google. Google utilizes the data collected to track and examine the use of www.prosperityca.com, to prepare reports on its activities and share them with other Google services.

Information may be used among companies that perform support services for us, such as data processors, technical systems consultants and programmers, or companies that help us market products and services to you for a number of purposes, including but not limited to:

• To protect your accounts from unauthorized access or identity theft;
• To process your requests such as securities purchases and sales;
• To establish or maintain an account with an unaffiliated third party, such as a clearing broker-dealer providing services to you and/or C2P Capital Advisory Group, LLC d.b.a. Prosperity Capital Advisors;
• To service your accounts, such as by issuing checks and account statements;
• To comply with Federal, State, and Self-Regulatory Organization requirements;
• To keep you informed about financial services of interest to you.

Regulation S-AM: Under Regulation S-AM, a registered investment adviser is prohibited from using eligibility information that it receives from an affiliate to make a marketing solicitation unless: (1) the potential marketing use of that information has been clearly, conspicuously and concisely disclosed to the consumer; (2) the consumer has been provided a reasonable opportunity and a simple method to opt out of receiving the marketing solicitations; and (3) the consumer has not opted out. C2P Capital Advisory Group, LLC d.b.a. Prosperity Capital Advisors does not receive information regarding marketing eligibility from affiliates to make solicitations.

Our Security Policy: We restrict access to nonpublic personal information about you to those individuals who need to know that information to provide products or services to you and perform their respective duties. We maintain physical, electronic, and procedural security measures to safeguard confidential client information.

Closed or Inactive Accounts: If you decide to close your account(s) or become an inactive customer, our Privacy Policy will continue to apply to you.

When Your Investment Advisor Representative Leaves PCA: PCA understands that the relationship you have with your advisor is important to you. If your advisor’s affiliation with PCA ends and they choose to move to a different financial institution, or if your advisor’s relationship with PCA is terminated, your PCA advisor may be allowed to take with them copies of all client and account documentation (including, but not limited to, account applications; account statements; and other pertinent forms and information related to you and your accounts), so your advisor is able to continue their relationship with you and service you through their new firm. PCA will also retain copies of your client and account documentation that was submitted with your account opening paperwork and any subsequent forms related to your account(s). Your advisor may keep your information on their own software systems. They are free to take that data with them unless you opt out. PCA does not keep copies of the information on your advisors software systems. You do not need to take any action if you choose to allow your PCA advisor to keep copies of your confidential information should they leave PCA.

If you do not want your advisor to keep copies of your confidential information should their affiliation with PCA end, you have the right to opt out*. If your account with us is a joint account, we will treat an opt-out request by any joint account owner as applying to all joint owners on the account. If you choose to opt out now, or at any time in the future, or wish to withdraw your opt-out request, please contact us by email at compliance@c2penterprises.com. If you choose to opt out, there will be a 30-day period before your opt out will take effect.

*PCA adheres to all applicable state and federal privacy regulations. Residents of Arizona, California, Connecticut, Georgia, Maine, Massachusetts, Minnesota, Montana, Nevada, New Jersey, New Mexico, North Carolina, North Dakota, Ohio, Oregon, Vermont, and Virginia will be provided an opportunity to opt in for information sharing per applicable state law. If you reside in one of these states, written authorization must be provided to your financial professional in order for them to take your information when they leave PCA.

The CCPA provides California Consumers with certain data rights with respect to your personal information.

You have the following “Rights to Know”:

• The specific pieces of personal information we have collected about you
• The categories of personal information we have collected about you
• The categories of sources from which your personal information is collected
• The categories of personal information that we have disclosed for a business purpose about you
• The categories of third parties to whom personal information was disclosed for a business purpose
• The business or commercial purpose for collecting, selling, or sharing personal information

You also have the right to:

• Request that we correct inaccurate personal information that we maintain about you
• Request that we delete personal information that we have collected from you (unless an exception applies, or deletion is otherwise restricted or prohibited by law, rule, or regulation)

You may exercise any of your data rights (subject to certain exceptions and limitations) by contacting us using the below information.

Changes to This Privacy Policy: If we make any substantial changes in the way we use or disseminate confidential information, PCA will notify you.

If you have any questions concerning this Privacy Policy, please contact us at:

Prosperity Capital Advisors
30400 Detroit Road, Suite 201
Westlake, Ohio 44145
(888)240-0064