Last Updated: December 22, 2021
At Cabana, we highly value the trust and confidence you place in us as advisors, which is why we want you to understand the personal information we collect from you and the efforts we take to protect and safeguard your privacy when we use your personal information.
Information about how we collect, use and share non-public personal information of current, former and prospective customers of Cabana is discussed in the Cabana Privacy Notice.
What Information Do We Collect and How Do We Collect It?
Depending on the way in which you interact with us and our Services we may collect several types of information from and about you, including personal information.
We collect some information directly from you when you provide it to us, such as when you correspond with us, fill out a form on our Website, submit information to our Services, fill out an online application for an investment advisory account or respond to a survey. This information may include your name, address, email address, telephone number, or any other identifier by which you may be contacted online or offline.
When you use the Cabana Advisor Tool, we collect and process your login credentials.
In addition to information you provide directly to us, we may use automatic data collection technologies to collect information automatically when you navigate through our Website or otherwise use our Services, including via cookies, pixels and web beacons. These technologies collect certain information about your device, equipment, browsing actions, and patterns. This information includes, for example, the websites that you access immediately before and after your visit to our Website, the Internet browser you are using, and your IP address or device ID. For more information see Cookies and Other Tracking Technologies below.
Cookies and Other Tracking Technologies
Web beacons. A “web beacon” is a one-pixel transparent image located on a Web page or in an e-mail or other type of message and is hosted on a server enabling the verification of a user’s viewing or receipt of a webpage or message. Web beacons can be used to track the IP (Internet Protocol) address of the computer or device that downloaded the page on which the web beacon appears, the URL (Uniform Resource Locator) of the page on which the web beacon appears, the time the page containing the web beacon was viewed, the type of browser used to access the webpage containing the web beacon and the identification number of any cookie on the computer or device previously placed by the server hosting the web beacon. When we correspond with you via HTML capable e-mail, Web beacons let us know whether you received and opened our e-mail.
Managing Your Preferences. If you would prefer not to accept cookies, most browsers or devices will allow you to: (i) change your browser or device settings to notify you when you receive a cookie, which lets you choose whether to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies and other similar technologies. Please note that doing so may negatively impact your experience using the Services, as some features of the Services may not work properly. Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject these technologies across all your browsers and devices, you will need to do so on each browser and device you actively use. You may also be able to set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have opened our e-mail and performed certain functions with it.
Do Not Track (DNT) Requests. Cabana does not currently recognize the “do not track” signals some browsers may employ.
How Do We Use the Information?
We may use the information you provide to us and that we collect from you through your use of the Services in order to respond to your inquiries about our products and services, to inform you of new products and services, to enable us to personalize your experience with our Website, to provide you requested services, to improve the design and content of our Website, to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, to notify you about changes to our Services or Website or any products or services we offer or provide through it, to allow you to participate in interactive features on our Website, and for any other purpose with your consent.
How Do We Share the Information?
We may disclose personal information that we collect or you provide through your use of our Website and the Services:
- to fulfill the purpose for which you provide it;
- to our parent, subsidiaries and affiliates;
- to contractors, service providers, and other third parties we use to support our business and who, where appropriate based on the services provided, are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
- to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Cabana’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Cabana about our Website users is among the assets transferred;
- for any other purpose disclosed by us when you provide the information;
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Cabana, our customers, or others; and
- to detect, prevent or otherwise address fraud, security or technical issues
- as may be required or permitted by law; and
- with your consent.
We may disclose aggregated information about our Website users and information that does not identify any individual, without restriction, unless otherwise prohibited by law.
Children Under the Age of 13
Our Website and the Cabana Advisor Tool are not intended for children under 13 years of age and anyone under the age of 13 is expressly prohibited from using the Website or the Cabana Advisor Tool or providing information to Cabana through the Website or the Cabana Advisor Tool. We do not knowingly collect personal information from children under 13. If Cabana learns we have collected or received personal information from a child under 13 years of age , we will delete that information to the extent possible. If you believe we might have any information from or about a child under 13, please contact us at: firstname.lastname@example.org.
Your California Privacy Rights
The California “Shine the Light Law,” California Civil Code Section 1798.83, permits California residents to request and obtain once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. California residents may make such a request in writing by emailing email@example.com with your name and address, and noting “California Shine the Light Request” in the subject line of the email.
Updating Your Information
If you need to edit or update your information, you may contact us at firstname.lastname@example.org.
Other Terms, Conditions and Disclosures
The Terms and Conditions for the Website can be found here, and additional written disclosure information can be found in Cabana’s Form ADV, Part 2A located here, and in Cabana’s Form CRS, located here. The Terms and Conditions for the Cabana Advisor Tool can be found here.