Copy of Privacy

Privacy Policy

Effective: July, 2024

Information we collect and why

In order to provide a high-quality service, Wavvest Wealth, LLC (Wavvest) collects various types of information when you visit the website or mobile app, sign-up as a customer, or otherwise engage with Wavvest.

Visitor information

We collect various types of anonymous information about visitors to Wavvest, such as device-related information (including browser type and IP address) and server log information (including the date and time of day of your visit, average time spent on the Wavvest site, browsing activity, and any site that referred you to Wavvest). We also collect information that you input into our website, such as your name, phone number, or email address when you begin the account application process or comment on the Wavvest blog. We use this information to better understand our visitors and our business, facilitate site navigation, provide the services or information you request, and enhance the Wavvest service. To the extent you enter identifying information as part of the account application process, we are required by law to store that information to comply with federal regulations.

Customer information

When you choose to create an account with Wavvest, we will also collect certain personal information, including your full legal name, email address, permanent address, date of birth, social security number and information about financial status. We are required by law to collect and store this information to provide you with financial services. If you do not wish to provide this information, you cannot become a Wavvest customer.

Wavvest offers account linking and aggregation services through Plaid Inc. ("Plaid"). Wavvest also uses Plaid for identity verification services. By using account linking and aggregation services, you acknowledge and agree that the terms of Plaid's Privacy Policy will govern Plaid's use of such information, and you expressly agree to the terms and conditions of Plaid's Privacy Policy. Further, you expressly grant Plaid the right, power, and authority to access and transmit your information as reasonably necessary for Plaid to provide these services to you. Wavvest will collect information about the transactions associated with, and the cash flows into and out of, accounts linked through Plaid.

Wavvest partners with April Tax Solutions Inc. (“April”) to offer tax prep and filing services. By using these, you acknowledge and agree to the terms of April’s Privacy Policy. Further, you expressly grant April the right, power, and authority to access, store, and transmit information as reasonably necessary for April to provide these services to you.

Wavvest partners with Ladder Insurance (“Ladder”) to offer term life insurance. By using these, you acknowledge and agree to the terms of Ladder’s Privacy Policy. Further, you expressly grant Ladder the right, power, and authority to access, store, and transmit information as reasonably necessary for Ladder to provide these services to you.

Wavvest partners with Apex Fintech Solutions (“APEX”) to provide custodial services. By using these, you acknowledge and agree to the terms of APEX’s Privacy Policy. Further, you expressly grant APEX the right, power, and authority to access, store, and transmit information as reasonably necessary for APEX to provide these services to you.

Wavvest partners with Proof (“Proof”) to provide digital notary services. By using these, you acknowledge and agree to the terms of Proof’s Privacy Policy. Further, you expressly grant Proof the right, power, and authority to access, store, and transmit information as reasonably necessary for Proof to provide these services to you.

Advisor information

We collect information from advisory firms that use the Wavvest platform, as well as from individual advisors, including but not limited to advisory firm and advisor names, email addresses, and other relevant information pertaining to advisors’ businesses. We also collect certain personal and financial information about advisory firm customers, who are Wavvest customers, as described above in the “Customer Information” section. Additionally, we collect information from advisors who are considering partnering with Wavvest.

Other ways we collect information

Apart from through the account opening process and from visitors to the site, we may collect various other types of personal information if you or a friend engages with Wavvest. We collect your email address as part of our customer referral service or if you subscribe to the Wavvest blog. We may also collect personal information if you enter it into our live chat program or contact us or otherwise give it to us (e.g., in an email, phone call, or live chat with a member of our customer support team). Further, we may collect information regarding your browsing activity when you visit Wavvest’s websites and actions you take within your Wavvest account while logged in to your Wavvest account.

Cookies and pixels

Cookies are small pieces of data that are stored on your computer, mobile phone or any other device used to access the internet. Pixels are small code blocks on a website that allow for another server to measure viewing of a webpage and often are used in connection with cookies.

We use these technologies to customize Wavvest and improve your experience with the site. Cookies store information, such as whether you viewed the site from your mobile device. We may store some personal information in a cookie and/or pixel, such as the site that you visited immediately prior to visiting Wavvest and relevant financial information that allows us to enhance your user experience and for marketing purposes. Additionally, we may use a cookie and/or pixel to track visitors across various websites or devices to better customize our marketing and advertising campaigns. We also offer certain tools from third-party service providers that may use cookies and/or pixels.

Certain cookies, pixels, and similar technologies are not required for site functionality. You are not required to accept non-functional cookies or pixels to use this site. However, refusing to accept these cookies or pixels will make the use of Wavvest more cumbersome and less accessible.

You may opt out of the use of cookies and pixels for behavioral advertising through the privacy controls on the Wavvest website.

Advertising companies

Wavvest advertises our services on websites not affiliated with Wavvest, and we contract with third-party advertising companies to display these ads. These third-party advertising companies, along with data exchanges and similar providers, may use cookies and similar technologies to collect technical and web navigational information, such as device type, browser type, IP address, and pages visited. We do not provide personally identifiable information to these advertising companies.

Wavvest and third-party advertising companies may use the data collected to provide you with ads relevant to you and personalized content while you are on Wavvest or other sites. If you prefer to not receive targeted advertising, you can opt out of some network advertising programs that use your information by visiting the NAI Opt-Out Page. You may also contact these third party companies directly to opt out of targeted advertising from Wavvest and/or any other firm. Please note that even if you choose to remove your information by opting out, you will still see advertisements while you are browsing online.

Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The NAI Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies. Because mobile devices may vary in how they operate and may not use cookies, the choice management options listed above may not work for all mobile devices and mobile apps.

Analytics services

We use third-party analytics tools, including Google Analytics (such tools collectively referred to as “Analytics Services”) to collect information about the usage of this site. The Analytics Services collect information about how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site, among other information. We use the information we get from these Analytics Services to improve this site.

These Analytics Services collect the IP address assigned to you on the date you visit this site, along with other anonymized information (e.g., browser type and type of device used to visit the site), but not your name or other personally identifiable information. The Analytics Services’ ability to use and share information about your visits to this site is restricted by their terms of use and privacy policies. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.

How we use your personal information

Wavvest uses your personal information to provide financial advice and other services; enhance your customer experience; improve our products and features; provide customer support; open, operate, and maintain your account in accordance with US law; investigate and understand how Wavvest is used; monitor and protect the security and integrity of Wavvest; and better market and advertise Wavvest’s services. If you link external accounts to your Wavvest account, we may use transactional data from those accounts to provide you with financial advice or to recommend additional Wavvest products and services to you. You understand and agree that Wavvest will compare your identifying information with government-provided lists of suspected terrorists.

As part of this process, we may from time to time include, compile, or aggregate some of your personal information in certain data analyses, reports, or other interpretations of investment trends for both internal and external purposes. When including, compiling, or aggregating personal information for such purposes, we make sure that the information is anonymized such that it is not identifiable to any particular customer.

Additionally, we, or our service providers, may use your personal information to contact you regarding Wavvest's services, resources, or Wavvest job openings that we think may be of interest to you. Please note that if you hold an account with Wavvest, you cannot opt out of certain communications related to the administration of your account, including communications related to billing, statement and trade confirmation delivery, or certain regulatory matters.

If Wavvest is unable to contact you over email because your email address returned an undeliverable message, you understand and agree that Wavvest may make alternative attempts to contact you via phone, SMS text, mail, or other communication means.

If you provide your phone number to Wavvest, Wavvest may contact you by phone regarding opening and/or funding an account. You may request to be put on a "Do Not Call" list maintained by Wavvest.

How we share your information

We do not sell, rent, or trade your personal information with any third parties other than with your consent or as required by law.

In order to provide financial services and in connection with our everyday business purposes and activities, we may share your personal information with third parties who perform services on our behalf. Examples of these third parties and services include consumer identification verification services and other professional firms, and certain other vendors and service providers who perform marketing, advertising, research and analytics services on our behalf. We have entered into agreements that require that these third parties keep this information confidential. We may also disclose your information to other third-party financial institutions, e.g., if you ask to transfer assets from Wavvest to such financial institutions.

We may also disclose personal information in response to service of legal process, such as a court order, summons, or subpoena, or as permitted or required by law when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud (including identity theft), frontrunning or scalping, situations involving potential threats to the physical safety of any person, or suspected violations of our Terms of Service or customer agreements. We also may disclose information about you if necessary to determine your eligibility to recover compensation in connection with class action lawsuits.

Furthermore, we may disclose personal information in specific other cases with your consent.

If you conduct business with us through Wavvest, we may exchange information we collect with your investment professional or with others they may authorize.

If you contact Wavvest Support, information you provide may be collected and used by third-party service providers to Wavvest or their service providers, which may process that information using generative artificial intelligence technology, including but not limited to large language models. Wavvest has received assurances that your personal information will not be used to train any of these models.

How we share your personal information for marketing and research analytics

As disclosed above, we use certain vendors and service providers who perform marketing, advertising, research and analytics services on our behalf.

These include platforms that monitor and provide analytics on our systems, applications that support automated emails for marketing efforts, applications that allow us to build personalized social media campaigns, and tools to record customer communication and interaction history. We use these service providers to comply with regulatory requirements, provide financial services, enhance your customer experience, improve our products and features, and provide customer support. These vendors and service providers with whom we share your personal information are bound by agreements with us to keep your personal information confidential and we never rent or sell your information to anyone.

We use reasonable efforts to limit the sharing of personally identifiable information with vendors and service providers when it is not reasonably required for the service and share anonymized or hashed information in lieu of personal information when it is practicable. Certain experiences on Wavvest's website and applications may entail engaging directly with third-party service providers. In such situations, you will be presented with terms and conditions that apply to the use of that service, which may include authorizing such service providers to use anonymized data from your engagement to improve their own products or services. For more information about anonymized information, see details below.

Opt-out information

You may opt out of promotional or marketing emails by clicking “unsubscribe”, which appears in the footer of such emails. If you no longer wish to receive text messages, please type "STOP" in response to any such text. You may also opt out from push notifications from the Wavvest application on your iOS or androidOS device.

Note that you cannot opt out of administrative communications, such as emails that contain account statements, notify you regarding changes to your account or contain updates to our terms and conditions

How to request deletion of the personal information we collect

Wavvest allows you to close your Wavvest accounts. Please note that we retain information on deleted accounts as required for legal, regulatory and security purposes.

How your personal information is protected

Wavvest works diligently to protect your personal information. We employ several physical and electronic safeguards to keep your information safe. We use the strongest available browser encryption, store all of our data on servers in secure facilities, and implement systematic processes and procedures for securing and storing data. We limit access to your personal and financial information to only those employees with authorized access who need to know the information in order to perform their jobs, and we require third parties who perform services for Wavvest to agree to keep your information confidential.

Furthermore, if you choose to close your account or your account is terminated with us, we will continue to adhere to the privacy policies and practices outlined here. If you maintain a Wavvest account that you access through our website or mobile apps, you are responsible for protecting and maintaining the confidentiality of your account and password and restricting access to your computer.

How you can access or change your personal information that we have collected

Once you have registered with Wavvest, you can access your profile, review the information that is stored, and revise that information. If you have any problems, you may also contact us at support@wavvest.com. Due to US regulatory requirements, we do not delete residual copies of outdated information and must preserve all customer data for a minimum of three years.

Anonymized information

We may share anonymized information that is summarized or derived from information you provide to us with third parties. Anonymous information is information that does not include any personally identifiable information. From time to time, Wavvest performs analysis on investing-related topics using anonymized and/or summarized insights from customers. Such research reports, blog posts, or findings may be shared with external publishers or published by us on financial topics of interest.

Other important information

Former customers

If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current customers. We preserve former customer data in order to comply with regulatory obligations.

How we respond to do not track signals

Online tracking is the collection of data about an individual’s Internet activity used to deliver targeted advertisements and for other purposes. Customers using certain modern browsers have the ability to activate a “Do Not Track” signal. Wavvest currently responds to the “Do Not Track” signal as required by certain states' laws.

How you accept this policy

By using and continuing to use the Wavvest websites, mobile apps and/or services, or otherwise providing us with personal information (such as an email address) you agree to the terms and conditions of this privacy policy and any updates thereto. This policy may change from time to time. This is our entire and exclusive privacy policy and it supersedes any earlier version. Our Terms and Conditions take precedence over any conflicting privacy policy provision.

Changes to the policy

We may modify this privacy policy over time without prior notice by posting a new version of this privacy policy, which is your responsibility to review. Any changes to the privacy policy will be reflected on this page and will become effective immediately upon posting. We encourage you to periodically review this privacy policy to stay informed about how we are protecting the personally identifiable information we collect. If changes to the privacy policy are material, we will do our best to notify you via email or through a notification on the site or app. Please check the effective date below to determine if there have been any changes since you have last reviewed the Wavvest privacy policy.

Children

Our service is not directed towards anyone under the age of 18. If a parent or guardian becomes aware that their child under the age of 18 has created an account with Wavvest and/or provided us with personally identifiable information, please contact us at support@wavvest.com Additionally, if we become aware at any point that a child under the age of 18 is using our service, we will terminate their account.

U.S. State Privacy Notice and California Notice at Collection

Several U.S. states, including California, have enacted or will soon enact consumer privacy laws that grant their residents certain rights and require additional disclosures (collectively, “State Privacy Laws”). If you are a resident of one of these states, this section applies to you and supplements the information contained in Wavvest’s Full Privacy Policy.

As explained in our privacy policy above, both federal and state laws require us to tell you how we collect, use, share, and protect your personal information. As a result, our data collection practices are generally governed by federal law, including the Gramm-Leach-Bliley Act (“GLBA”). However, certain information collected is covered by State Privacy Laws. This may include information related to cross-contextual behavioral advertising or targeted advertising. Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“CPRA”) of 2020 and other California laws (collectively, the “CCPA”), this may also include information about employees and employee applicants as well as enterprise data (such as business-to-business).

This notice is intended to provide information required under State Privacy Laws, including the CCPA. This notice applies to the data collection and processing practices of Wavvest.

We do not and will not sell consumer personal information in the traditional and colloquial sense of the word “sale.” We do use advertising technology on our website, which under some State Privacy Laws may be considered a “sale” or “share” of your information. We do not exchange our clients’ personal information for monetary payments. As discussed below, you may opt-out of targeted advertising at any time on our website. We also do not offer financial incentives, preferential service agreements, or any other differences in our prices or services in exchange for your data. For more information see below “Right to Opt-Out of Sale/Sharing.”

We disclose the following categories of personal information to third parties for the purpose of engaging in targeted advertising and other marketing activities, including to expand the reach and effectiveness of our marketing campaigns. These disclosures may be considered “sales” or “sharing” or use of personal information for “targeted advertising” under certain State Privacy Laws.

Exercising Your privacy choices and rights

Under the State Privacy Laws, you may have the rights to access, delete, and correct your personal data, to opt out of “sales” or “shares” of your personal data, and to limit the use and disclosure of your sensitive personal information, subject to certain exceptions under federal law, including the Gramm-Leach-Bliley Act (“GLBA”). We may deny your Data Subject Requests to delete if your data is:

Not protected under CCPA;
Subject to retention under federal law or regulation;
Necessary for us or our service providers to:
- Detect security incidents,
- Protect against malicious, deceptive, fraudulent, or illegal activity,
- Assist law enforcement in prosecuting those responsible for such activities, or
- Comply with a legal obligation.

To request to exercise any of these rights, please email support@wavvest.com, including sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

We will make every effort to verify your identity using your email address, but we may request additional information. If an authorized representative is making the request on your behalf, we require documentation showing that the representative has such authority. You may only make a verifiable Data Subject Request for access or data portability twice within a 12-month period.

Right to delete

Under certain State Privacy Laws, you have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your Data Subject Requests, we will delete your personal information from our records (and direct our service providers to delete your personal information from their records), unless an exception applies.

Certain personal information that we collect and use to provide you with financial services, and which Wavvest is obligated by federal law and/or regulations to retain, cannot be deleted upon request.

Right to correction

Under certain State Privacy Laws, you have the right to request that we correct any inaccuracies about your personal information. If we provide you with financial services, you can do so through our application

Right to know/right to access and data portability rights

Under certain State Privacy Laws, you have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we confirm your Data Subject Request, we will disclose to you, upon specific request:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting, disclosing, or sharing that personal information.
The categories of third parties with whom we disclose that personal information.
The categories of personal information we disclosed or sold to each category of third party.
The specific pieces of personal information we collected about you.

Right to opt-out of sale/sharing

Certain State Privacy Laws require that we provide transparency about personal information we use for targeted advertising. Wavvest shares personal information with marketing vendors for the commercial purpose of placing relevant content and advertisements for you on our own websites and apps, as well as other websites, online media channels, and apps. As noted above, although this use of personal information may constitute a “sale” of personal information under certain State Privacy Laws, Wavvest never receives monetary payments in exchange for personal information that we collect from you.

Right to limit use and disclosure of sensitive personal information

We already limit the use of sensitive personal information only to the purpose of providing you with the financial services we offer. Therefore, our use of this information cannot be further limited by request.

We cannot respond to your Data Subject Request or provide you with personal information if we are unable to verify your identity, or unable to verify the authority for the person making the request as your agent. We will use personal information provided in a verifiable consumer Data Subject Request to verify your identity or authority to make the Data Subject Request, and not for any other purpose.

Response timing and format

We will acknowledge your Data Subject Request within 10 days. We attempt to respond to every Data Subject Request within 45 days. If we require more time, we will inform you of the reason and how much additional time we require (up to 90 days in total). Any disclosures we provide may only cover the 12-month period preceding the Data Subject Request’s receipt. If we are unable to satisfy your Data Subject Request, or a part of your Data Subject Request, we will explain why.

We do not charge a fee to process or respond to Data Subject Requests.

Authorized agent

Only you, or a person you have designated in writing as your authorized agent, or who is registered with the applicable Secretary of State to act on your behalf, or to whom you have provided power of attorney pursuant to applicable laws, (“Authorized Agent”), may make a verifiable consumer request to access, port, correct, or delete your personal information. You may also make a verifiable consumer request on behalf of your minor child.

If you wish to have an Authorized Agent make a request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your Authorized Agent, and we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information.

California-specific notices

If you are a California resident, California Civil Code Section 1798.83 permits you to request a list of all third parties to which we, during the immediately preceding calendar year, have disclosed certain personally identifiable information for direct marketing purposes.

We are only required to respond to a customer request for this list once during any calendar year. To make such a request, please see above under the section “Exercising Your Privacy Choices and Rights.” Please be aware that not all information sharing is covered by the California privacy rights requirements and only information sharing that is covered will be included in our response.

The following chart shows details about the Data Subject Requests we received under CCPA from January 1, 2024, to December 31, 2024:

1 Fulfilled means any requests that were fulfilled in whole or fulfilled to the extent allowable under applicable law and regulations, including federal law and regulation.

2 Denials do not include requests that are determined to be inapplicable because they are received from non-California residents and/or request information that is not covered under CCPA.

During the last twelve (12) months, we have likely collected personal information in the following categories from consumers and disclosed personal information with the following categories of recipients. Although the list contains examples of information likely collected, we do not collect every specific piece of personal information for every consumer:

We collect personal information for the business and commercial purposes and uses described in the above section in the Full Privacy Policy.

In addition to the sources described in the section above entitled “Information We Collect and Why,” we collect personal information from the following categories of sources:

Directly from our clients or their agents,
Indirectly from our clients or their agents, in the course of the services that we provide,
Directly and indirectly from activity on our website,
Other third-party sources, including government sources, data brokers and social networks, and
From third parties that interact with us in connection with the services we perform.

The retention periods for data elements within each category listed above vary depending on the nature of the data element and the purposes for which it is collected and used. Our retention period for the data elements within each category is set based on the following criteria:

The length of time that the data is needed for the purposes for which it was created or collected,
The length of time the data is needed for other operational or record retention purposes,
The length of time the data is needed in connection with our legal, compliance and regulatory requirements, for legal defense purposes and to comply with legal holds,
How the data is stored,
Whether the data is needed for security purposes and fraud prevention, and
Whether the data is needed to ensure the continuity of our products and services.

Non-discrimination

We will not discriminate against you for exercising any of your rights. Unless permitted by the State Privacy Laws, we will not:

Deny you services.
Charge you different prices for our services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of service.

Questions

If you have any questions on the privacy policy, please contact us at:

Wavvest Wealth, LLC
24 E Washington St, Chicago, IL 60602
support@wavvest.com
630-699-8602