Written Procedures and Safeguards Designed to Protect the Privacy of Customer Records and Information

Cash Flow Stewardship, Inc. (“CFS”) has adopted the following written procedures and safeguards addressing administrative, technical and physical safeguards for the protection of customer records and information.  These written procedures and safeguards are designed to (a) ensure the security and confidentiality of customer records and information, (b) protect against anticipated threats or hazards to the security or integrity of customer records and information and (c) protect against unauthorized access to or use of customer records or information that could result in substantial harm or inconvenience to any customer.  The term “customer” as used herein has the meaning provided in Regulation S‑P as adopted by the Securities and Exchange Commission (“SEC”).

CFS collects personal information from customers for account related purposes, such as processing corporate consulting services and providing other investor services. The personal information that CFS collects includes (i) information on agreements and other forms completed by investors, (ii) information from discussions and written correspondence with customers and (iii) information about customers’ transactions.

1. Confidentiality of Customer Information and Records.  CFS policy is that all customer information and records are to be kept strictly confidential, and under no circumstances is any of such information or records to be revealed to or shared with any other person who is not authorized to have access to and use of such information and records, regardless of whether such person is another employee of CFS, an employee of an affiliate of CFS, or a third person, in each case unless the customer specifically consents to or directs the disclosure. CFS will provide third party service providers with access to customer information as necessary to carry out their responsibilities to the customer’s accounts.  CFS and the third-party service providers are required to maintain and protect the confidentiality of such information.

1. Persons who are authorized to have access to and use of such information will be limited to those individuals that are determined to have a legitimate business reason for having access to and use of the information.

CFS is committed to the protection and privacy of its customers’ and consumers’ personal, corporate and financial information. CFS will not share such information with any affiliated or nonaffiliated third party except:

• When necessary to complete a transaction in a customer account, such as with an account custodian;
• When required to maintain or service a customer account;
• To resolve customer disputes or inquiries;
• With persons acting in a fiduciary or representative capacity on behalf of the customer;
• With persons assessing compliance with industry standards, or to the attorneys, accountants and auditors of the firm;
• In connection with a sale or merger of CFS business;
• To protect against or prevent actual or potential fraud, identity theft, unauthorized transactions, claims or other liability;
• To comply with federal, state or local laws, rules and other applicable legal requirements;
• In connection with a written agreement to provide services when the information is released for the sole purpose of providing the services covered by the agreement;
• In any circumstances with the customer’s instruction or consent; or
• Pursuant to any other exceptions enumerated in the Nebraska Information Privacy Act.

1. Training of Employees.  Each employee who will have access to customer records and information will be instructed immediately upon hiring and regularly reminded that CFS policy is that all customer records and information, including without limitation the name, address, phone number, email address, and all information about the customer’s account, is to be held in strict confidence and is not to be revealed to or discussed with any person who is not formally authorized hereunder to have access to such information, in the absence of a specific customer consent to or direction of a disclosure.

1. Access to Electronic Records.  Customer records and information will be kept on computer systems only under conditions such that access to such information and records is limited to those employees who have been specifically authorized to have such access. Such persons shall be identified when logging onto the system by the use of a password known only to such person (and the system administrator).  The computer system will automatically require periodic changes in such passwords.  Records and information regarding customers shall be kept only on a specifically designated portion of the network utilized by CFS, and such network shall at all times be maintained so that all users of the system other than those specifically authorized as above shall not have the ability to access the portion of the network on which information and records of customers are maintained.  

1. Paper Records.  Current information with respect to each customer and all related records and information shall be kept within specifically designated areas occupied by persons authorized to have access to such information and records, and in no other place. Older records may be kept in a records center, but the personnel of such records center shall at all times be trained to release information and records relating to customers only from the individuals specifically authorized by CFS to have access to and use of such records.

1. Physical Access to Fund Premises.  Physical access to CFS premises or any building in which CFS records are kept shall be limited to employees CFS and to visitors who have a legitimate reason for being at such premises.

1. Sharing Information with Affiliated Entities.  Regulation S-AM prohibits a registered investment adviser from using information about an individual consumer that has been obtained from an affiliated entity for marketing purposes unless the information sharing practices have been disclosed and the consumer has not opted out.

It is not a policy of CFS to share nonpublic personal and financial information with affiliated or unaffiliated third parties except under the circumstances noted above. Since sharing under the circumstances noted above is necessary to service customer accounts or is mandated by law, there are no allowances made for clients to opt out.

In June/July of every year, in accordance with Regulation S-P and Regulation S-AM, CFS shall send, or shall authorize another service provider to send, CFS privacy statement to all customers. CFS shall review and update, if necessary, these procedures on an annual basis.

Privacy Statement

CASH FLOW STEWARDSHIP, INC. (“CFS” or the “Firm”) considers privacy to be fundamental to our relationship with our clients. We are committed to maintaining the confidentiality, integrity and security of our clients, and investors’ non-public information. Accordingly, we have developed internal policies to protect confidentiality while allowing investors’ needs to be met. This statement applies to former as well as current investors.

We respect your right to privacy. We also know, however, that you expect us to conduct our investment program in an accurate and efficient manner.  To do so, we must collect personal information from clients or our investors for business related purposes, such as processing transactions and providing other investor services.

CFS is required to maintain and protect the confidentiality of such information. We maintain physical, electronic, and procedural safeguards to protect personal information.  We may share personal information described above with other affiliated parties for business purposes such as processing investor transactions and requests. 

During regular business hours access to customer records is monitored so that only those with approval may access the files. During hours in which the company is not in operation, the customer records will be locked.

No individual who is not so authorized shall obtain or seek to obtain personal and financial customer information. No individual with authorization to access personal and financial customer information shall share that information in any manner without the specific consent of a Firm Principal. Failure to observe CFS procedures regarding customer and consumer privacy will result in discipline and may lead to termination.

The personal information we collect may include but is not limited to:

• information on agreements and other forms completed by investors (such as an investor’s name, address and social security number or other tax identification number);
• information from discussions and written correspondence with investors; and 
• information about investors’ transactions.

CFS collects and manages non-public personal information about our investors and customers that CFS uses as part of our day-to-day business operations. CFS is committed to the protection and privacy of its customers’ and consumers’ personal and financial information. CFS will not share such information with any affiliated or nonaffiliated third party except:

• When necessary to complete a transaction in a customer account, such as with an account custodian;
• When required to maintain or service a customer account;
• To resolve customer disputes or inquiries;
• With persons acting in a fiduciary or representative capacity on behalf of the customer;
• With rating agencies, persons assessing compliance with industry standards, or to the attorneys, accountants and auditors of the firm;
• In connection with a sale or merger of CFS business;
• To protect against or prevent actual or potential fraud, identity theft, unauthorized transactions, claims or other liability;
• To comply with federal, state or local laws, rules and other applicable legal requirements;
• In connection with a written agreement to provide services when the information is released for the sole purpose of providing the services covered by the agreement;
• In any circumstances with the customer’s instruction or consent; or
• Pursuant to any other exceptions enumerated in the California Information Privacy Act.

It is not a policy of CFS to share nonpublic personal and financial information with affiliated or unaffiliated third parties except under the circumstances noted above. Since sharing under the circumstances noted above is necessary to service customer accounts or is mandated by law, there are no allowances made for clients to opt out.

We endeavor to keep our customer files complete and accurate.  We should be notified if any information needs to be corrected or updated.  Questions about this privacy notice should be addressed to:

Chief Compliance Officer
Cash Flow Stewardship, Inc.
4611 S 96^th Street, Suite 248
Telephone: 402-804-3777