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. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the stated categories in this Privacy Policy exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. End users can opt out of receiving further messages by replying STOP or request more information by replying HELP. Message frequency varies. Message and data rates may apply.

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.

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 driver´s 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 client

regulations (including social security number, tax status, income and assets);

- Protected classification characteristics under state 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.

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 applicable privacy laws, 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 service to you.

How to Exercise Your Rights

To exercise any of your rights under applicable privacy laws, 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 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), we may request additional information in order to verify your request. You may designate an authorized agent to make a request 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: CALIFORNIA RESIDENTS

California 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 Office of the California Attorney General at P.O. Box 944255, Sacramento, CA 94244; phone (916) 210-6276.

PRIVACY NOTICE SUPPLEMENT: COLORADO RESIDENTS

Colorado Law requires us to disclose that you may request to be placed on our ´do not call´ list atat any time by calling us at (702) 569-7316. To obtain further information, contact The Office of the Attorney General, Colorado Department of Law at 1300 Broadway, 10th Floor, Denver, CO 80203; phone (720) 508-6000.

PRIVACY NOTICE SUPPLEMENT: FLORIDA RESIDENTS

Florida Law requires us to disclose that you may request to be placed on our ´do not call´ list atany time by calling us at (702) 569-7316. To obtain further information, contact The Office of the Attorney General, PL-01 The Capitol, Tallahassee, FL 32399-1050; phone (866) 966-7226.

PRIVACY NOTICE SUPPLEMENT: NORTH CAROLINA RESIDENTS

North Carolina Law requires us to disclose that you may request to be placed on our ´do not call´ list at list at any time by calling us at (702) 569-7316. To obtain further information, contact The Office of the Attorney General, 9001 Mail Service Center, Raleigh, NC 27699-9001; phone (919) 716-6400.

PRIVACY NOTICE SUPPLEMENT: 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 (888) 434-9989; email [email protected].

PRIVACY NOTICE SUPPLEMENT: UTAH RESIDENTS

Utah 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 Office of the Attorney General, P.O. Box 142320, Salt Lake City, UT 84114; phone (801) 366-0260; email [email protected].

PRIVACY NOTICE SUPPLEMENT: VIRGINIA RESIDENTS

Virginia 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 Office of the Attorney General, 202 North Ninth Street, Richmond, VA 23219; phone (804) 786-2071.