Privacy Policy

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Maintaining the trust and confidence of our clients is a high priority. That is why we want you to understand

how we protect your privacy when we collect and use information about you, and the steps that we take to

safeguard that information. This notice is provided to you on behalf of Planning Trail Investments, LLC

(“Planning Trail”).

 

Information We Collect: In connection with providing investment products, financial advice, or other services, we

obtain non-public personal information about you, including:

 

• Information we receive from you on account applications, such as your address, date of birth, Social Security Number, occupation, financial goals, assets and income;

• Information about your transactions with us, our affiliates, or others;

• Information about your visit to our website. We store that information in web server logs, which are records of the activities on our sites. The servers automatically capture and save the information electronically. The information we collect in web server logs helps us administer the site, analyze its usage, protect the website and its content from inappropriate use and improve the user’s experience.

 

Categories of Information We Disclose: We may only disclose information that we collect in accordance with this

policy. Planning Trail does not sell customer lists and will not sell your name to telemarketers.

 

Categories of Parties to Whom We Disclose: We will not disclose information regarding you or your account at

Planning Trail, except under the following circumstances:

 

• To entities that perform services for us or function on our behalf, including financial service providers, such as a clearing broker-dealer, investment company, or insurance company, other investment advisers;

• To consumer reporting agencies,

• To third parties who perform client resource management or other parties to help manage your account on our behalf;

• To your attorney, trustee or anyone else who represents you in a fiduciary capacity;

• To our attorneys, accountants or auditors; and

• To government entities or other third parties in response to subpoenas or other legal process as required by law or to comply with regulatory inquiries.

 

How We Use Information: Information may be used among companies that perform support services for us, such as

data processors, client relationship management technology, technical systems consultants and programmers, or

companies that help offer our services to you for a number of purposes, such as:

 

• To protect your accounts/non-public information from unauthorized access or identity theft;

• To process your requests such as securities purchases and sales;

• To establish or maintain an account with an unaffiliated third party, such as a clearing broker-dealer providing services to you and/or Planning Trail;

• To service your accounts, such as by issuing checks and account statements;

• To comply with Federal, State, and Self-Regulatory Organization requirements;

• To keep you informed about financial services of interest to you.

 

Regulation S-AM: Under Regulation S-AM, a registered investment adviser is prohibited from using eligibility

information that it receives from an affiliate to make a marketing solicitation unless: (1) the potential marketing use of

that information has been clearly, conspicuously and concisely disclosed to the consumer; (2) the consumer has

been provided a reasonable opportunity and a simple method to opt out of receiving the marketing solicitations; and (3) the consumer has not opted out. Planning Trail does not receive information regarding marketing eligibility from

affiliates to make solicitations.

 

Our Security Policy: We restrict access to nonpublic personal information about you to those individuals who need

to know that information to provide products or services to you and perform their respective duties. We maintain

physical, electronic, and procedural security measures to safeguard confidential client information.

 

Cyber Security: Internal policies and procedures are in place to address cyber security. A copy of this policy is

available upon request.

 

Departing Investment Adviser Representatives (“IARs”): If your IAR’s affiliation with Planning Trail ends and he or she

joins a non-affiliated securities broker-dealer or registered investment adviser, Planning Trail will permit the IAR to use

certain client contact information to solicit clients to join the IAR's new firm. The client contact information that the IAR

may use is limited to your name, address, email address, phone number and account title.

 

Certain states have adopted a requirement for you to approve the sharing of information in advance, otherwise known

as an “opt-in” choice. If you live in an “opt-in” state (e.g., California, Massachusetts, Maine, Alaska, North Dakota or

Vermont), then Planning Trail will require your consent to share your information with unaffiliated third parties who are not servicing your account. State requirements vary and may change without notice.

 

Succession Planning: In the event that the owner(s) of Planning Trail retire, become incapacitated or perish

unexpectedly, your information would be disclosed to an unaffiliated third party for the purposes of facilitating a

business succession plan. A change in control of ownership of Planning Trail would require your consent, as dictated by

your signed agreement with Planning Trail, in order to continue providing services to you.

 

Your Right to Opt Out: Federal privacy laws give you the right to restrict some sharing of your personal financial

information. These laws balance your right to privacy with Planning Trail's’ need to provide information for normal business purposes. You have the right to opt out of some information sharing with companies that are (1) Part of the same

corporate group as your financial company (or affiliates); or (2) Not part of the same corporate group as your financial

company (or non-affiliates). Choosing to restrict the sharing of our personal financial information will not apply to (1) Records of your transactions--such as your loan payments, credit card or debit card purchases, and checking and

savings account statements--to firms that provide data processing and mailing services for your company; (2)

Information about you in response to a court order; and (3) Your payment history on loans and credit cards to credit

bureaus. If you opt out, you limit the extent to which Planning Trail can provide your personal financial information to non-affiliates.

 

Closed or Inactive Accounts: If you decide to close your account(s) or become an inactive customer, our Privacy

Policy will continue to apply to you.

 

Complaint Notification: Please direct complaints to: Alex Carvalho, Chief Compliance Planning Trail Investments, LLC at (303) 519-0506.

 

Changes to This Privacy Policy: If we make any substantial changes in the way we use or disseminate confidential

information, we will notify you. If you have any questions concerning this Privacy Policy, please contact us at:

Planning Trail Investments at (303) 519-0506.