PRIVACY POLICY AND PRACTICES LAST UPDATED: MARCH 2024
Oaks Valley Financial Services LLC dba Wakeful (“Wakeful,” “we,” “our,” or “us”) Privacy Policy explains how Wakeful collects, uses, and discloses information about you. Wakeful recognize and respect the privacy expectations of our customers. We do not sell information about current or former customers or their accounts to third parties. We provide this notice to you so that you will know what kinds of information we collect about customers and the circumstances in which that information may be disclosed.
SECTION 1
1. COLLECTION OF CUSTOMER INFORMATION Information You Provide to Us
To use the full Wakeful App (the “Platform”), you must sign a Term of use contract and a RIA agreement and/or create an account. In doing so, we collect information you provide directly to us. For example, you share information directly with us when you create an account, fill out a registration form, submit content through our Platform, request customer support, or otherwise communicate with us. The types of personal information we may collect include your name, email address, postal address, phone number, professional or employment-related information such as company name or representatives’ names, risk tolerance, financial status and objectives, demographic information, and any other information you choose to provide.
Information We Collect Automatically When You Interact with Us
When you access or use our Platform or otherwise transact business with us, we automatically collect certain information, including: - Activity Information: We collect information about your activity on our Platform, such as data displayed. - Transactional Information: When we/you make an investment allocation, we collect information about the allocation, such as asset details, purchase price, and the date and location of the transaction. - Device and Usage Information: We collect information about how you access our Platform, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Platform, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Platform. - Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Platform and your experience, see which areas and features of our Platform are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Platform and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness.
Information We Collect from Other Sources
We obtain information from third-party sources. For example, if you create or log into your account through a third-party platform (such as Apple and/or Google), we will have access to certain information from that platform, such as your name, email, birth date and telephone number, in accordance with the authorization procedures determined by such platform. The information we collect from these third-party sources is used, stored and safeguarded as described below.
SECTION 2
2. USE OF INFORMATION We use the information we collect to provide, maintain, administer and improve the Platform. We also use the information we collect to: - Authenticating your identity and processing account applications with Interactive Brokers; - Ensure proper functioning of the Platform; - Provide services, content, material and other information on the Platform; - Display your information and share investment-related information; - Process transactions and send you related information, including confirmations, receipts, invoices, customer experience surveys, and recall notices; - Personalize and improve your experience on our Platform; - Identify and/or diagnose problems on or related to our Platform; - Send you technical notices, security alerts, and support and administrative messages; - Provide requested information, technical support and/or integrations such as an application programming interface or API; - Respond to your comments and questions and provide customer service; - Communicate with you about products, the Platform, virtual events we may offer and provide news and information we believe will interest you; - Monitor and analyze trends, usage, and activities in connection with our Platform; - Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect our and others’ rights and property; - Debug to identify and repair errors in our Platform; - Comply with our legal and financial obligations; - Carry out any other purpose described to you at the time the information was collected; and - For other reasonable internal use or uses aligned with your relationship with us and the context in which we collected the information.
SECTION 3
3. SHARING OF INFORMATION We share personal information in the following circumstances or as otherwise described herein: - We share personal information with vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as: identification verification, processing account applications, trade processing, data management, fraud prevention, customer service. - We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Wakeful, our users, the public, or others. - We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests. - We share personal information with your consent or at your direction.
We will not disclose any of the customer information we collect to third parties who are not affiliated with Wakeful other than:
- to effect or administer transactions at your request.
- as permitted or required by law or regulation – for example, in connection with an audit or examination, or to respond to a subpoena or similar legal process.
Wakeful may disclose any of the customer information it collects to its affiliates that are engaged in a variety of financial services businesses, both in connection with the servicing of customer accounts and to inform clients of financial products and services that might be of interest.
SECTION 4
4. TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES Wakeful is headquartered in the United States, and we may have operations and service providers in the United States and Latin America. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.
SECTION 5
5. YOUR CHOICES
Account Information You may update and correct certain account information at any time by logging into your account. If you wish to deactivate your account, please do so from your account profile on the website or mobile application, but note that we may retain certain information as required by law or for our legitimate business purposes.
Cookies Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Platform.
Communications Preferences You may opt out of receiving promotional emails from Wakeful by following the instructions in those communications or by logging into your account. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
Mobile Push Notifications With your consent, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
SECTION 6
6. POLICY PRIVACY CHANGES Wakeful may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, when material, we will provide you with additional notice (such as adding a statement to our website or sending you a notification) and consent when required under applicable law. Your continued use of this Platform after we make such changes is deemed to be acceptance of those changes when permissible. We encourage you to review this Privacy Policy periodically to stay informed about our information practices and the choices available to you.
SECTION 7
7. SECURITY OF CUSTOMER INFORMATION We have physical, electronic and procedural safeguards to protect nonpublic personal information of our customers. We will adhere to the policies and practices described in this notice regardless of whether you are a current or former customer. Wakeful may restrict access to client nonpublic personal information by, among other things, password-protecting electronic information, having such information in a designated location that is not accessible to all employees, or otherwise segregating such information.
SECTION 8
8. CONTACT US
If you have any questions about this Privacy Policy, please contact us at: Email: [email protected] Postal address: 1395 Brickell Av, Suite 800, MIAMI, Florida, 33131.