GDPR Privacy Policy Notice

Last updated January 1, 2020

OUR COMMITMENT TO PROTECT YOUR PRIVACY

Creative Planning, LLC (“Creative Planning,” “we,” “us,” or “our”) maintains physical, electronic, and procedural safeguards that comply with federal standards such as the Gramm-Leach-Bliley Act (“GLBA”) and the European Union’s (“EU”) General Data Protection Regulation (“GDPR”) to protect its clients’ nonpublic personal information (“Personal Information”) as defined under GLBA, and to the extent applicable, “personal data” as defined under the GDPR. For the purposes of this policy, “personal data” means information that can directly or indirectly, identify an individual person and specifically includes, but is not limited to, a client’s name, address, birthdate, social security number, bank account number(s), tax identification number, other government-issued identification numbers; other forms and documents a client sends to us; and any other information about a client’s transactions with us.

This policy shall also include “Personal Data” that we collect on our firm’s website (“Site”), such as cookies. Through this policy and its underlying procedures, Creative Planning 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.

You can find out more about Creative Planning at www.creativeplanning.com or by contacting us using the information in the contact us section.

HOW AND WHAT TYPE OF PERSONAL INFORMATION WE COLLECT

To conduct regular business, Creative Planning may collect personal information from sources such as:

Personal Information reported by the client on applications or other forms the client provides to the firm
Personal Information about the client’s transactions implemented by the firm or others
Personal Information developed as part of financial plans, analyses or investment advisory services
Personal Information collected on our website such as cookies.

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

Information Creative Planning receives from the client on applications (name, social security number, address, assets, etc.), from third parties authorized to share your information with us, from Cookies, or from publicly available information
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 transaction with Creative Planning

In addition to the above, other specific types of Personal Information Creative Planning collects includes, but is not limited to: birthdate, bank account number(s), tax identification number, other government-issued identification numbers; other forms and documents client sends to Creative Planning, information to create client’s online account.

HOW WE USE YOUR PERSONAL INFORMATION

Creative Planning will only use your Personal Information for the purpose of providing investment advisory services to you, including, but not limited to: (1) to monitor, audit, evaluate and otherwise administer our services; (2) to communicate with you; (3) in an effort to protect against fraud and identity theft; (4) comply with applicable legal requirements, relevant industry standards, contractual obligations, and our policies and terms; and (5) for other purposes as required or authorized by law, including other purposes for which you have provided your consent and our legitimate interests.

LAWFUL BASIS TO PROCESS YOUR PERSONAL INFORMATION

To lawfully process your Personal Information, Creative Planning retains one or more of the following lawful bases: (1) your voluntary consent in connection to providing you with Creative Planning’s investment services; (2) as necessary in order to fulfill certain contractual obligations; (3) as necessary to comply with applicable rules, laws, and regulations; and (4) as necessary in connection to the legitimate interests of our firm and/or a third party.

YOUR RIGHTS AND LIMITS ON SHARING

In terms of your rights, to the extent permitted by applicable law, you may request: (1) to have your Personal Information corrected; (2) to opt out of receiving marketing communications at any time; (3) to file a complaint with an applicable government regulator; (4) to access the Personal Information Creative Planning holds about you; (5) to restrict or object to the processing of your Personal Information, or request that your Personal Information is erased; (6) to receive a copy of the Personal Information you have provided to Creative Planning, in a structured, commonly used format (known as “data portability”); (7) have a copy of your Personal Information provided to you or another controller where technically feasible; (8) to withdraw your consent to Personal Information that you provided to us voluntarily, or otherwise consented to its use.

To the extent U.S. Federal laws apply to your Personal Information, you have the right to limit only: (i) sharing for affiliates’ everyday business purposes; (ii) affiliates from using your Personal Information to market to you; and (iii) sharing for nonaffiliates to market to you. U.S. state laws and individual companies may give you additional rights to limit sharing.

Creative Planning may share your Personal Information for its everyday business purposes such as maintaining your account(s) or responding to court orders and legal investigations. For these types of purposes, you cannot limit sharing. We do not use your Personal Information to market our services to you. Moreover, Creative Planning does not share your Personal Information with “nonaffiliated” companies for marketing purposes or for “joint marketing” purposes as those terms are defined under applicable U.S. Federal law.

As discussed above, we will endeavor to ensure your Personal Information is kept accurate, complete, up to date and relevant. Please let us know if any of your details change. If you feel your Personal Information is not accurate, complete or up to date, please notify us and we will take reasonable steps to ensure it is corrected. Additionally, you have the right to know what kind of information we collect and retain about you, to have reasonable access to it and to request a copy of it. You can contact us to request this information using the details listed below.

In accordance with the foregoing, Creative Planning may take steps to verify your identity before granting you access to your Personal Information.

HOW WE MAY SHARE YOUR PERSONAL INFORMATION WITH THIRD PARTIES

Since Creative Planning shares nonpublic information solely to service client accounts, the firm does not disclose any nonpublic personal information about the firm’s customers or former customers to anyone, except as permitted by law, such as to government entities, consumer reporting agencies or other third parties in response to subpoenas. In the event that the firm has a change to its customer privacy policy that would allow it to disclose non-public information not covered under applicable law, the firm will allow its clients the opportunity to opt out of such disclosure.

HOW LONG WE RETAIN YOUR PERSONAL INFORMATION

To the extent permitted by applicable law, Creative Planning retains your Personal Information for the period necessary to serve the purposes for which Creative Planning obtained it. Creative Planning may also retain your Personal Information beyond such period in accordance with applicable laws, regulations, or another lawful basis, including but not limited to, compliance with our contractual obligations, legal obligations, regulatory obligations, legal claims, or another legitimate interest.

HOW WE MAINTAIN ACCURACY OF YOUR PERSONAL INFORMATION

Creative Planning will endeavor to ensure your Personal Information is kept accurate, complete, up to date and relevant. Please let Creative Planning know if any of your details change. If you feel your Personal Information is not accurate, complete or up to date, please notify us and we will take reasonable steps to ensure it is corrected. You can contact us in the Contact Us section below.

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.

DATA CONTROLLER

To the extent GDPR applies, Creative Planning is the data controller for this policy located at the address below.

ADDITIONAL PERSONAL INFORMATION ABOUT OUR SITE

For additional information about our Site policies, please refer to the section below titled, “Web Site Appendix.”

CHANGES TO THIS POLICY

Creative Planning will provide each client with initial notice of the firm’s current policy when the client relationship is established. Creative Planning shall also provide each such client with a new notice of the firm’s current privacy policies at least annually. If, at any time, Creative Planning adopts material changes to its privacy policies, the firm shall provide each such client with a revised notice reflecting the new privacy policies.

U.S. CONSUMER PRIVACY POLICY

Individual consumers who are customers or former customers of Creative Planning, please refer to the Creative Planning US Privacy Policy. The privacy policies describe the information collected, with whom the information is shared, and how the information is protected and safeguarded.

NOTICE TO CALIFORNIA CLIENTS REQUIRED BY STATE LAW

California residents, please click here.

CONTACT US

Should you have any questions regarding the above, please contact:

Ken Pyle, Chief Compliance Officer
5454 W 110th Street
Overland Park, KS 66211

Direct: 1.913.338.2727
Fax: 1.888.243.9402

WEBSITE APPENDIX

SECURITY

As our Site is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of Personal Information you communicate to us online. We also cannot guarantee that the Personal Information you supply will not be intercepted while being transmitted over the internet. Accordingly, any Personal Information or other information which you transmit to us online is transmitted at your own risk.

LINKS TO THIRD-PARTY WEBSITES

As a convenience to you, Creative Planning may provide hyperlinks to websites operated by third parties. When you select these hyperlinks, you will be leaving our Site.

Creative Planning has no control over third party websites, their content, or security. Accordingly, when you access these third party websites it is at your own risk. We encourage you to read the associated privacy policies by such third party websites to learn more about their data privacy management practices. Creative Planning may, in its sole discretion, block links to our Site without prior notice.

COOKIES

We may use “cookies” to help us tailor our Site to better suit your needs (for example, we may use cookies to enable us to save any personal preferences indicated by you) and to provide a more effective route to various components of our Site.

For more information on how our firm utilizes cookies and how you may disable them, please refer to our Cookie Policy.

DO WE RESPOND TO DO NOT TRACK SIGNALS?

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers and is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across Sites or online services.

We do not track users across time or over multiple websites, we do not receive, or respond to, browser do-not-track signals or other similar mechanisms. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.

To learn more about setting up a Do Not Track signal, please visit https://allaboutdnt.com/.

CHILDREN

Our Site is not directed to children under the age of 18 years. By using our Site, 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 “Personal Data” from children under the age of 18 through this web site. However, we may process personal data, on a child’s behalf, with permission from the parent or guardian.

To the extent we have unintentionally collected any Personal Data on our Site from a person under the age of 18 years old, you may request and obtain removal of this Personal Data. 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.