Privacy Policy

Pursuant to applicable federal and/or state privacy regulations, The Planning Center, Inc. (referred to as “TPC”) is a financial institution that has determined to keep confidential nonpublic personal information about each TPC client.
 
Nonpublic personal information is defined to mean personally identifiable financial information that is provided by a consumer to a financial institution, results from any transaction with the consumer or any service performed for the consumer, or is otherwise obtained by the financial institution.
 
Personally identifiable financial information means any information: (1) a consumer provides to a financial institution to obtain a financial product or service; (2) about a consumer resulting from any transaction involving a financial product or service between a financial institution and a consumer; or (3) a financial institution otherwise obtains about a consumer in connection with providing a financial product or service to that consumer.
 
Attached hereto and made a part hereof is a copy of TPC’s Privacy Notice to be distributed by TPC:  (1) initially: (a) to each existing TPC client; and (b) to each new client prior to or at the time of establishing a “customer relationship” with TPC; and (2) annually thereafter for as long as the client maintains its relationship with TPC.
 
The purpose of TPC’s Privacy Notice, Privacy Policy as well as its underlying procedures is to protect the confidentiality and security of its clients’ nonpublic personal information.  The categories of nonpublic personal information that TPC collects from a client depend upon the scope of the client engagement.  It may include information about the client’s personal finances, information about the client’s health to the extent that it is needed for the planning process, information about transactions between the client and third parties, and information from consumer reporting agencies.  TPC has instituted certain technical, administrative and physical safeguards through which TPC seeks to protect this nonpublic personal information about current and former clients from unauthorized use and access.  First, technical procedures are used in order to limit the accessibility and exposure of client information contained in electronic form.  Second, administrative procedures are used in order to control the number and type of employees, affiliated and nonaffiliated persons, to whom customer information is accessible.  Third, physical safeguards have been established to prevent access to client information contained in hard-copy form.  As illustrated above, TPC realizes the importance of information confidentiality and security, and emphasizes practices which are aimed at achieving those goals.
 
By executing this document in the space provided below, you acknowledge, understand, and accept: (1) your obligation to comply with TPC’s Privacy Policy as set forth on the attached Privacy Notice; (2) that your knowing or reckless violation of this Privacy Policy will result in discipline by TPC, including the potential termination of your employment; and (3) that if you have any question(s) regarding any aspect of the Privacy Policy, including exceptions thereto, you shall immediately address such question(s) with Eric Kies, Chief Compliance Officer, prior to taking any action that could result in the violation of the Privacy Policy.  A complete copy of the applicable federal and/or state privacy regulations is available for your review upon request.
 
 
PRIVACY NOTICE
 
The Planning Center, Inc. (referred to as “TPC”) maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information (“information”).  Through this policy and its underlying procedures, TPC attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.
 
It is the policy of TPC to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide products or services in furtherance of the client’s engagement of TPC.  In that regard, TPC may disclose the client’s information: (1) to individuals and/or entities not affiliated with TPC, including, but not limited to the client’s other professional advisors and/or certain service providers that may be recommended or engaged by TPC in furtherance of the client’s engagement of TPC (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, record keeper, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations.  The disclosure of information contained in any document completed by the client for processing and/or transmittal by TPC to facilitate the commencement/continuation/termination of a business relationship between the client and/or between TPC and a nonaffiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, record keeper, insurance company, etc.), including, but not limited to, information contained in any document completed and/or executed by the client in furtherance of the client’s engagement of TPC (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider.
 
TPC permits only authorized employees and affiliates who have signed a copy of TPC’s Privacy Policy to have access to client information.  Employees violating TPC’s Privacy Policy will be subject to TPC’s disciplinary process.  Additionally, whenever TPC hires other organizations to provide services to TPC’s clients, TPC will require them to sign confidentiality agreements and/or the Privacy Policy.
 
Should you have any questions regarding the above, please contact Eric Kies, Chief Compliance Officer.