Privacy Policy

NOTIFICATION OF PRIVACY POLICIES AND PRACTICES  

(“Privacy Notice”)  

Maintaining the confidentiality and security of the personal information of our current and  prospective clients is one of our highest priorities. This notice sets forth the type of personal  information we collect, how that information is used by us, and how we protect your  personal information. 

Information We Collect  

In connection with providing investment advisory services to you, non-public personal  information is collected from the following sources:  

From You: We collect information from you in conversations over the telephone, in  voice mails, through written correspondence, via e-mail and other electronic  communications or in client agreements, questionnaires, account applications or  other forms (including, without limitation, any anti-money laundering, identification,  and verification documentation) that you complete when requesting information or  services from us. This information may include, among other things, items such as  your name, address, email address, social security number, birth date, annual  income, net worth, and marital status. 

From Transactions: We collect information about your transactions with us or  others and keep records of advice or services we provide. We keep records  relating to items such as your account balance and payment history, which  enables us to resourcefully service your account. 

From our Web Site or Client Portal: If you visit our website, we may use a so-called  cookie to track the amount of time you spend on our site, the parts of our site you  visited, and other technical information. We use this information to improve the  functionality of our web site. Additionally, we collect registration information and  information provided through online forms. Your personal information is collected  and maintained by us so we may develop, offer, and deliver products and services  to you, process transactions in your account, and fulfill our legal and regulatory  requirements. 

Information We Disclose  

We do not disclose any non-public personal information about our clients, prospective  clients or former clients to anyone, except as permitted or required by law, or as necessary  to affiliates and service providers. We may disclose all of the information we collect, as  described above, to certain non-affiliated third parties such as, but not limited to,  custodians, software providers, attorneys, accountants, auditors, compliance and other 

consultants, banks, lenders, governmental agencies and other persons or entities to enable  us to provide requested services to you and to comply with legal and regulatory  requirements, as well as pursuant to legal process and to self-regulatory organizations.

1 

Protection of Your Personal Information  

Our employees may, from time to time, have access to your personal information in order  to provide services to you. All employees are subject to the terms of our company’s  compliance manual, which requires employees to treat confidentially all information  obtained from or about you or your account. We also maintain physical, electronic, and  procedural safeguards designed to protect nonpublic personal financial information. 

Further Information 

We reserve the right to change our privacy policies and this Privacy Notice at any time. Any  examples contained within this notice are illustrations only and are not intended to be  exclusive. This notice complies with the privacy provisions of Regulation S-P under the  Gramm-Leach-Bliley Act and certain privacy provisions of other laws. You may have  additional rights under other foreign or domestic laws that apply to you, including as set  forth in our additional and/or supplemental privacy notices. 

PRIVACY NOTICE SUPPLEMENT FOR CALIFORNIA RESIDENTS  

This notice supplements the Privacy Notice set forth above with respect to specific  rights granted under the California Consumer Privacy Act of 2018 (the “CCPA”) to natural  person California residents and provides information regarding how such residents can  exercise their rights under the CCPA. This supplement is only relevant to you if you are  a resident of CA as determined in accordance with the CCPA. Information required to  be disclosed to CA residents under the CCPA regarding the collection of their personal  information that is not set forth in this CCPA supplement is otherwise set forth above in  the Privacy Notice. To the extent there is any conflict with the privacy requirements  under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights  shall apply. 

Categories of Personal Information We Collect  

We have collected some or all of the following categories of personal information from  individuals within the last twelve (12) months:  

▪ Identifiers, such as name, contact details and address (including physical  address, email address and Internet Protocol address), and other identification  (including social security number, passport number and drivers’ license or state  identification card number); 

▪ Other customer records, such as telephone number, signature, bank account  number, other financial information (including accounts and transactions with  other institutions and anti-money laundering information), and verification  documentation and information regarding clients’ status under various laws and  regulations (including social security number, tax status, income and assets); 

▪ Protected classification characteristics under CA or federal law, such as date of  birth, citizenship and birthplace; 

▪ Commercial information, such as account data and other information contained  in any document provided by clients to authorized service providers (whether  directly or indirectly), risk tolerance, transaction history, investment experience  and investment activity; and  

▪ Internet or other electronic network activity information, such as information  regarding your use of our website and client portal (e.g., cookies, browsing  history and/or search history), as well as information you provide to us when  you correspond with us in relation to inquiries.

2  

Within the last twelve (12) months, we have shared each of the categories of personal  information collected with affiliates and third-party service providers as set forth in  “Information We Disclose” in the Privacy Notice above, and we collect personal  information from the sources set forth in “Information We Collect” in the Privacy Notice  above. 

Purposes for Collecting Personal Information  

We may collect or share the personal information we collect about you for one or more  of the following business or commercial purposes: 

• performing services to you, including but not limited to:  

• executing transactions in your account;  

• evaluating retirement plan options;  

• providing multigenerational wealth transfer advice;  

• financial planning, including without limitation estate planning advice; • assisting your tax preparer in preparing your federal and/or state tax  returns; 

• keeping you informed about our business; 

• monitoring our compliance with federal and state securities laws; • providing you with reporting on the performance or status of your  account(s); 

• pursuant to regulatory inquiry; 

• detecting security incidents, protecting against malicious, deceptive,  fraudulent or illegal activity; and 

• pursuant to lawfully obtained subpoena. 

WE DO NOT SELL ANY OF THE PERSONAL INFORMATION WE COLLECT ABOUT  YOU TO THIRD PARTIES.  

Deletion Rights  

You have the right to request that we delete any of your personal information that we  retain, subject to certain exceptions, including, but not limited to, our compliance with  U.S., state, local and non-U.S. laws, rules and regulations.  

Disclosure and Access Rights 

You have the right to request that we disclose to you certain information regarding our  collection, use, disclosure and sale of personal information specific to you over the last  twelve (12) months. Such information includes: 

▪ The categories of personal information we collected about you; ▪ The categories of sources from which the personal information is collected; ▪ Our business or commercial purpose for collecting such personal information; ▪ Categories of third parties with whom we share the personal information; ▪ The specific pieces of personal information we have collected about you; and ▪ Whether we disclosed your personal information to a third party, and if so, the  categories of personal information that each recipient obtained. 

No Discrimination  

We will not discriminate against you for exercising your rights under the CCPA, including  by denying service, suggesting that you will receive, or charging, different rates for  services or suggesting that you will receive, or providing, a different level or quality of 

3 

service to you. 

How to Exercise Your Rights  

To exercise any of your rights under the CCPA, or to access this notice in an alternative  format, please submit a request using any of the methods set forth below.  

Via email: to [email protected] 

Via telephone: Please submit your request and telephone number by email to [email protected] and we will call you during our normal business  hours.  

We will contact you to confirm receipt of your request under the CCPA and request any  additional information necessary to verify your request. We verify requests by matching  information provided in connection with your request to information contained in our  records. Depending on the sensitivity of the request and the varying levels of risk in  responding to such requests (for example, the risk of responding to fraudulent or  malicious requests). You may designate an authorized agent to make a request under  the CCPA on your behalf, provided that you provide a signed agreement verifying such  authorized agent’s authority to make requests on your behalf, and we may verify such  authorized person’s identity using the procedures above. 

I give you permission to share my personal information:  

Signature of Client(s): _____________________________  

Printed Name: ___________________________________ 

Our goal is to respond to any verifiable consumer request within forty-five (45) days of  our receipt of such request. We will inform you in writing if we cannot meet that timeline.  Please contact Austin Peterson, the Chief Compliance Officer of Backbone Planning  Partners LLC at [email protected] with any questions about this Privacy  Notice. 

PRIVACY NOTICE SUPPLEMENT FOR NEVADA RESIDENTS  

Nevada law requires us to disclose that you may request to be placed on our “do not  call” list at any time by calling us at 702-569-7316. To obtain further information, contact  the Bureau of Consumer Protection, Office of the Nevada Attorney General at 555 E.  Washington Ave., Suite 3900, Las Vegas, NV 88101; phone 1.702.486.3132; email  [email protected].