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CS Planning Corp. Privacy Policy

Policy

As a Registered Investment Adviser, CS Planning Corp. (“CSP” or the “Firm”) must comply with the rules under Regulation S-P, or other applicable regulations, which require Registered Investment Advisers and other SEC regulated entities to adopt policies and procedures to protect the “non-public personal information” of clients who are natural persons and to disclose to such persons the Firm’s policies and procedures for protecting that information. Further, the Firm must comply with SEC Regulation S-AM, to the extent that the firm has affiliated entities with which it may share and use consumer information received from affiliates. CSP must also comply with the California Financial Information Privacy Act (SB1) when it does business with California clients.

Regulation SP

The purpose of the Regulation S-P requirements and these privacy policies and procedures is to provide administrative, technical and physical safeguards which will assist CSP employees in maintaining the confidentiality of non-public personal information (“NPI”) collected from the clients(consumers and customers) of an investment adviser. All NPI, whether relating to an adviser’s current or former clients, is subject to these privacy policies and procedures. Any doubts about the confidentiality or treatment of client NPI must be resolved in favor of confidentiality.

Non-Personal Information

For Reg S-P purposes, NPI includes non-public “personally identifiable financial information” plus any list, description or grouping of clients that is derived from non-public personally identifiable financial information. Such information may include personal financial and account information, information relating to services performed for or transactions entered into on behalf of clients, advice provided by CSP to clients, and data or analyses derived from such NPI.

SEC Regulation S-AM requires SEC investment advisers and other SEC regulated entities, to the extent relevant, to implement limitations on the Firm’s use of certain consumer information received from an affiliated entity to solicit that consumer for marketing purposes. Regulation S-AM also provides for notice and opt-out procedures, among other things.

The Chief Compliance Officer (the “CCO”) is responsible for reviewing, maintaining and enforcing these policies and procedures to assure, at a minimum compliance with applicable federal and state laws and regulations. To this end, the CCO is responsible for distributing these policies and procedures to all employees and conducting appropriate training. As appropriate, the CCO may also recommend to the Firm’s principals that disciplinary or other action be taken against any employee who violates or disregards these policies and procedures.

CSP has adopted various procedures to implement the Firm’s policy and conducts reviews to implement, monitor, and update these policies and procedures, as appropriate. These include the following:

CSP maintains safeguards in order to comply with federal and state standards to guard each client’s non-public personal information(“NPI”), and CSP does not share NPI with any non-affiliated third parties, except in the following circumstances:
1. As necessary to provide the service that the client has requested or authorized and to maintain and service the client’s account;
2. As required by regulatory authorities or law enforcement officials who have jurisdiction over CSP or as otherwise required by law; and
3. To the extent reasonably necessary to prevent fraud or unauthorized transactions.
Employees, both during and after the termination of their employment with CSP, are prohibited, from disclosing NPI to any person or entity outside of CSP, including family members, except under the circumstances described above. An employee is permitted to disclose NPI only to other employees who need access to such information in order for CSP to service the client.
Any CSP employee who is authorized to have access to NPI is required to secure all such information. To this end, all electronic or computer files containing NPI shall be password secured and firewall protected from access by unauthorized persons. Any conversations in which NPI must be discussed must be conducted by employees in private, and care must be taken to avoid any unauthorized person from overhearing or intercepting such conversations.

Safeguarding standards encompass all aspects of CSP that affect security. This includes not just computer security standards but also such areas as physical security and personnel procedures. Examples of important safeguarding standards that CSP has adopted include the following:

Access controls for client information systems, including controls to authenticate and permit access only to authorized individuals and controls to prevent employees from providing client information to unauthorized individuals who may seek to obtain this information through fraudulent means (for example, requiring employee use of User ID numbers and passwords.)
Access restrictions and intruder detection devices at physical locations containing client information, such as branch offices, computer and record storage facilities.
Encryption or password protection of electronic client information, including while in transit or while stored on networks or systems to which unauthorized individuals may have access;
Monitoring systems and procedures to detect actual or attempted attacks or intrusions into client information systems (for example, monitoring of data for detection of loss, accidental or intentional manipulation);
Response programs that specify actions to be taken when the firm suspects or detects that unauthorized individuals have gained access to client information systems, including appropriate reports to regulatory and law enforcement agencies.
Measures to protect against destruction, loss, or damage to client information due to potential environmental hazards, such as fire and water damage, or technological failures (for example, making use of fire resistant storage facilities and vaults; backing-up and storing key data offsite to ensure proper recovery);

Any employee who is authorized to possess “consumer report information” for a business purpose is required to take reasonable measures to protect against unauthorized access to the information.

The Firm has determined that when NPI or other confidential client information is to be disposed of, a professional document destruction company will be utilized. Physical documents will be securely shredded, and electronic information will be destroyed using whatever methods are currently industry standard.