Privacy Policy Notice

What information we collect

We collect nonpublic personal information about you that you provide to us, or that we obtain with your authorization. Depending on the services you engage us to provide, this may include:

1. your name, address, telephone number, and email address;
2. your Social Security or taxpayer identification number and date of birth;
3. your income, assets, liabilities, and net worth;
4. your investment holdings, account numbers, and account balances;
5. your bank account information, where you authorize us to arrange transfers;
6. information about your employment, family, goals, and financial circumstances that you provide in the course of financial planning; and
7. copies of documents you provide, such as tax returns, trust instruments, entity documents, and account statements.

We collect this information because we cannot provide advice suited to your circumstances without it. We do not collect more than we need, and we do not require you to provide information that is not relevant to the services you have engaged us to provide.

How and whether we share it

The table below lists the reasons a financial company may share personal information, whether MWM shares for that reason, and whether you can limit it.

The short version. We share your information only to run the business you have engaged us to run, and only with parties who need it to do that. We do not sell it, we do not share it so that anyone can market to you, and we have no affiliates with whom we share it.

Who we share it with, and why

To provide our services we share information with parties who need it to perform a function for you or for us. These are the everyday business purposes referred to above, and they include:

1. the qualified custodians that hold your accounts, and the insurance carriers and mutual fund companies that issue contracts or hold accounts we manage, so that your accounts can be opened, maintained, and traded;
2. the third-party investment managers and model providers we may select for your account;
3. service providers that support our operations, such as our portfolio accounting and reporting systems, financial planning software, client relationship management system, document storage, email and communications archiving, and business valuation tools;
4. our accountants, auditors, attorneys, and compliance consultants, where necessary to obtain professional services;
5. your own accountant, attorney, or other professional, where you direct us to; and
6. regulators, courts, and law enforcement, where required or permitted by law, including in response to a subpoena, court order, examination, or regulatory request.

Each of these is a permitted use under the exceptions in Rule 248.13, Rule 248.14, and Rule 248.15 of Regulation S-P. We require the service providers we engage to protect the information we give them, to use it only for the purpose we gave it to them, and to notify us promptly if it is exposed.

Your right to limit sharing

Federal law gives you the right to limit three specific kinds of sharing. They are: sharing with our affiliates for their everyday business purposes based on information about your creditworthiness; sharing with our affiliates so that they can market their products and services to you; and sharing with companies that are not affiliated with us so that they can market to you.

MWM does not share your information for any of those purposes. We have no affiliates with whom we share your information, we have no joint marketing agreements, and we do not give your information to anyone so that they can market to you. Because we do not share in any of the ways federal law allows you to limit, there is no opt-out election for you to make. If our practices ever change so that any of the above applies, we will notify you and give you the opportunity to opt out before we share.

You can still ask us to restrict how we use your information. The sharing described earlier in this notice — with the custodians that hold your accounts, with the service providers that support our operations, and with your own professionals at your direction — is what allows us to provide the services you have engaged us to provide, and federal law does not give you a right to limit it. It is not marketing, and we receive nothing for it. If you would nonetheless like us to restrict a particular use, or to stop sharing with a particular provider, tell us and we will discuss what is possible while still serving you. Some restrictions may limit the services we can provide.

You may also tell us how you prefer to be contacted, including asking us not to contact you by a particular method or not to send you material about services you have not engaged us to provide. State law may give you additional rights, and nothing in this notice limits them.

To make any request under this section, contact Rodd Robert Miller, Chief Compliance Officer, at 480-613-7400 or [email protected].

Annual notices

We give you this notice when you become a client and whenever we change our privacy policies and practices in a way this notice would need to describe. Because we share your information only under the exceptions described above, we are not required under Rule 248.5(e) of Regulation S-P to send you this notice every year, and we do not intend to send one where nothing has changed. If our practices change so that the exception no longer applies, we will resume sending an annual notice and will tell you what changed. You may request a current copy of this notice at any time at no charge.

How we protect your information

We maintain written policies and procedures designed to protect your information, including physical, administrative, and technical safeguards. Access is limited to those who need it to serve you. Electronic records are stored on password-protected and encrypted systems, and we require multi-factor authentication for access to systems holding client information. Paper records are kept secured. We dispose of information we no longer need in a manner designed to prevent it from being read or reconstructed.

If your information is exposed. We maintain a written incident response program designed to detect, respond to, and recover from unauthorized access to or use of your information. If we determine that your sensitive information was, or is reasonably likely to have been, accessed or used without authorization, we will notify you as soon as practicable and in any event no later than thirty days after we become aware of the incident, unless we determine that the information has not been and is not reasonably likely to be used in a manner that would result in substantial harm or inconvenience. Our notice will describe what happened, what information was involved, and what you can do.

Former clients

If you stop being a client, we continue to protect your information as described in this notice, and we continue to share it only for the everyday business purposes described above. We keep your records for the period our regulatory recordkeeping obligations require, and dispose of them afterward in the manner described above.

Definitions

Affiliates are companies related by common ownership or control. MWM has no affiliates with which it shares your personal information. Nonaffiliates are companies not related by common ownership or control. MWM does not share your information with nonaffiliates so that they can market to you. Joint marketing is a formal agreement between financial companies that are not affiliated to market financial products or services together. MWM has no joint marketing agreements.

Questions

If you have any question about this notice or about how we handle your information, contact Rodd Robert Miller, Chief Compliance Officer, at 480-613-7400. Your privacy, our professional ethics, and our ability to provide you with quality financial services all matter to us.