Customer Privacy Policy Notice

In November of 1999, Congress enacted the Gramm-Leach-Bliley Act (GLBA).  The GLBA requires certain financial institutions, such as investment advisor firms, to protect the privacy of customer information.  Federal law gives clients the right to limit some but not all sharing of your personal information. In situations where a financial institution does disclose customer information to nonaffiliated third parties, other than permitted or required by law, clients must be given the opportunity to opt out or prevent such disclosure.  Creative Planning, LLC and its Affiliates (collectively, "Creative Planning," "we," "our," or "us") does not share or disclose customer information to nonaffiliated third parties except as permitted or required by law.

Commitment to Your Private Information.  Creative Planning is committed to safeguarding the confidential information of its clients.  We hold all personal information provided by clients in the strictest confidence and it is the objective of the firm to protect the privacy of all clients.  Except as permitted or required by law, we do not share confidential information about clients with nonaffiliated parties.  In the event that there were to be a change in this policy, the firm will provide clients with written notice and clients will be provided an opportunity to direct us as to whether such disclosure is permissible.

Why We Collect and How We Use Information.  To conduct regular business, Creative Planning collects personal information from sources such as:

• Information reported by the client on applications or other forms the client provides to us
• Information about the client’s transactions implemented by the firm or others
• Information developed as part of financial plans, analyses or investment advisory services

To administer, manage, service, and provide related services for client accounts, it is necessary for us to provide access to customer information within the firm and to nonaffiliated companies with whom the firm has entered into agreements.  To provide the utmost service, we disclose the information below regarding clients and former clients, as necessary, to companies to perform certain services on our behalf.

• Information we receive from the client on applications (name, social security number, address, assets, etc.)
• Information about the client’s transactions with the firm or others (account information, payment history, parties to transactions, etc.)
• Information concerning investment advisory account transactions
• Information about a client’s financial products and services transactions with us

Sharing Information with Other Companies Permitted Under Law.  Since we share nonpublic information solely to service client accounts, the firm does not disclose any nonpublic personal information about the firm’s clients or former clients to anyone, except as permitted by law.  However, the firm may also provide customer information outside of the firm as required by law, such as to government entities, consumer reporting agencies or other third parties in response to subpoenas. Additionally, we do not jointly market with affiliated or nonaffiliated companies.

In the event that we have a change to our customer privacy policy that would allow us to disclose nonpublic information not covered under applicable law, we will allow clients the opportunity to opt out of such disclosure.

Entities with whom we may share nonpublic information include affiliated companies, such as our tax, legal, and insurance affiliates and non-affiliated companies, e.g. custodian. Information is shared so that your account can be opened at the custodian and to enhance our service offering to you by consulting with our tax, legal, and insurance affiliates, as necessary, to provide you with accurate and timely advice on your financial situation.  We may also share your non-public information with parties acting at your request and on your account.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes without consent. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties without consent.

How We Protect Your Information

Creative Planning and its affiliates maintain a comprehensive information security program designed to ensure the security and confidentiality of customer information, protect against threats or hazards to the security of such information and prevent unauthorized access. This program includes:

• Procedures and specifications for administrative, technical and physical safeguards.
• Security procedures related to the processing, storage, retention and disposal of confidential information.
• Programs to detect, prevent and, when necessary, respond to attacks, intrusions or unauthorized access to confidential information.
• Restricting access of customer information to employees who need to know that information to provide products and services to you and appointing specific employees to oversee our information security program.

Children. Our website is not directed to children under the age of 18 years. By using our website, you represent and warrant that you are at least 18 years old.

We respect the privacy of children and do not knowingly collect or retain personally identifiable information or nonpublic information from children under the age of 18 through our website. However, we may process nonpublic information, on a child’s behalf, with permission from the parent or guardian.

To the extent we have unintentionally collected any nonpublic information on our website from a person under the age of 18 years old, you may request and obtain removal of this nonpublic information. To make such a request, please send an email with a detailed description of the specific content or information to [email protected].

Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Former Clients.  Even if we cease to provide you with financial products or services, our Privacy Policy will continue to apply to you and we will continue to treat your nonpublic information with strict confidentiality.

Residents of the European Union (EU).  Residents of the EU can find Creative Planning’s General Data Protection Regulation (GDPR) Privacy Policy Notice by clicking on the GDPR Privacy Policy link on our website at creativeplanning.com.

Residents of California. Under the California Consumer Privacy Act of 2018 (the “CCPA”) as amended, California residents have certain rights around our collection, use and sharing of their personal information. Residents of California can find our CCPA Privacy Policy Notice by clicking on the CCPA Privacy Policy link on our website at creativeplanning.com.

Residents of States other than California. Some states have passed their own laws regarding data privacy, which have certain rights around Creative Planning’s collection, use, and sharing of their personal information. If you wish to submit an information request, please navigate to creativeplanning.truyo.com (Creative Planning’s Data Privacy Portal) and complete a request.

Cookie Policy. You can find our policy on how Creative Planning collects and uses cookies by clicking on the Cookie Policy link on our website at creativeplanning.com/cookie-policy.

Changes to this Policy. We will provide each client with initial notice of the current Privacy Policy when the client relationship is established.  Additionally, we may occasionally amend this Privacy Policy at any time. If we decide to use personal information in a manner that is materially different from that stated at the time it was collected, we will notify you of such changes prior to implementing them by posting a revised Privacy Policy with a new “Last Updated” date. We will also provide each client with the current Privacy Policies at least annually.

We encourage you to check our website frequently to see when this Privacy Policy was last revised and to be informed of how we are committed to protecting your information.

Any Questions regarding this Disclosure Brochure or US Privacy Policy Notice may be directed to Lee Richardson, Chief Compliance Officer at [email protected] or 866-909-5148. Note that information requests must be made via Creative planning’s Data Privacy Portal at creativeplanning.truyo.com.