Jan 6, 2020
This notice is provided to you by Cabana, LLC (dba “Cabana Asset Management”), Cabana Advisors, LLC, Cabana Financial, LLC, Cabana Law Group, Cabana Retirement Solutions, and The Cabana Group, LLC (collectively, “Cabana”).
At Cabana, we highly value the trust and confidence you place in us as advisors, which is why we want you to understand how we collect, protect and safeguard your privacy when we use your personal information.
What Information Do We Collect?
We collect several types of information from and about users, including:
- Personally Identifiable Information, such as your name, address, email address, telephone number, or any other identifier by which you may be contacted online or offline. If you voluntarily submit information to our Website or mobile applications, for example, in an online application for an investment advisory account, we may record and use any personally identifiable information, such as your name, phone number and e-mail address, for reasonable business purposes including, but not limited to, fulfilling your request. If you need to edit or update your information, you may contact us at firstname.lastname@example.org or for mobile application users, you may do so directly by editing your account profile.
(b) information that is about you but does not identify you individually; and/or
(c) Technical Information. We may record certain non-identifiable information that becomes available to us as a result of your visit to our Website, including, without limitation, the number and frequency of visitors to our website. 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. If we use such data at all, it will be on an aggregate basis, and we will not disclose to third parties any information that could be used to identify you personally.
How Do We Collect the Information?
As you navigate and experience our Website, you may interact with various features that collect information both directly from you when you provide it to us and automatically as you navigate through the site.
The information we may collect directly from you includes:
- Copies of correspondence, if you contact us.
- Information that you provide by completing forms on our Website (i.e. subscription services and requests for additional information) or mobile applications.
- Your responses to surveys.
- Your search queries on the Website.
In addition to information you provide directly to us, we may use automatic data collection technologies to improve and enhance your experience with the Website, including cookies and web beacons, which collect certain information about your equipment, browsing actions, and patterns.
A “cookie” is a small text file created by a website that is stored in the user’s computer either temporarily for that session only or permanently on the hard disk. Cookies provide a way for our Website to recognize you and keep track of your preferences.
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. On their own, cookies or web beacons do not contain or reveal any personally identifiable information; however, if you choose to furnish the Website with personally identifiable information, this information can be linked to the data stored using cookies and/or web beacons.
You may adjust your browser to reject cookies from us or from any other website. If you have a Flash player installed on your computer, your Flash player may be able to be set to reject or delete Flash cookies. Please consult the “Help” section of your browser or Flash player for more information. Additionally, by setting your Web browser to display HTML emails as text only, you may be able to prevent the use of some web beacons. However, certain areas of our Website may only be accessed in conjunction with cookies or similar devices, and you should be aware that disabling cookies or similar devices might prevent you from accessing some of our content.
How Do We Use the Information?
We may use the information you provide to us through your use of the Website or mobile applications 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 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 Disclose the Information?
We restrict the disclosure of your personal, non-public and confidential information. We only disclose your information as indicated or as required by law. In accordance with Section 248.13 of Regulation S-P (and S-AM), we may disclose all of the information we collect, as described above, to certain non-affiliated third parties such as attorneys, accountants, auditors and persons or entities that are assessing our compliance with industry standards.
We may disclose aggregated information about our Website users and information that does not identify any individual, without restriction, unless otherwise prohibited by law. We may disclose personal information that we collect or you provide through your use of our Website:
- to fulfill the purpose for which you provide it;
- to our subsidiaries and affiliates;
- to contractors, service providers, and other third parties we use to support our business and who 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; and/or
- with your consent.
We may also disclose your personal information:
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request; and/or
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Cabana, our customers, or others.
Children Under the Age of 13
Cabana is committed to the protection of children’s online privacy. The Children’s Online Privacy Protection Act (COPPA) governs information gathered online from or about children under the age of 13. Our Website is not intended for children under 13 years of age and anyone under the age of 13 is expressly prohibited from using the Website and/or providing information to Cabana through this Website. 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 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at: email@example.com
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 firstname.lastname@example.org with your name and address, and noting “California Shine the Light Request” in the subject line of the email.
Cabana uses technical, physical and administrative safeguards to help protect the personal information entrusted to it. However, we cannot guarantee the security of our Website, and all transmissions online entail risk. Do not send any sensitive information to us through our Website or through any other unsecured channel.
To contact us with your questions or comments regarding this policy or the information collection and dissemination practices of the Website, please email us at email@example.com.
Other Terms, Conditions and Disclosures
Cabana is a U.S. Securities and Exchange Commission (SEC) Registered Investment Adviser (RIA) with headquarters in Fayetteville, Arkansas. Cabana is in compliance with the current registration and/or notice filing requirements imposed upon SEC registered investment advisors by those states in which Cabana maintains clients. Cabana may only transact business in those states in which it is registered, or qualifies for an exemption or exclusion from registration requirements. The Terms and Conditions for the Website can be found at https://thecabanagroup.com/terms/ and additional written disclosure information can be found in Cabana’s ADV, Part 2 which can be found at the following link: https://thecabanagroup.com/wp-content/themes/cabana/disclaimers/Cabana%20Form%20ADV%20Part%202A%20%2012-24-2019.pdf.