Effective January 1, 2020

Willow Wood Financial, its affiliate, subsidiary and parent companies understands that you care about how we collect, use, and share information when you interact with our websites, social media sites and handles, email, and online services (our “Services”), and we value the trust you place in us. This Privacy Policy explains:

• – the types of information we collect through our Services
• – how we use and protect that information
• – the types of information we may share with others and under what circumstances
• – the choices you have regarding our collection, use, and sharing practices
• – details regarding our use of third-party cookies and other tracking technologies

We also include specific disclosures for residents of California. 

This Policy applies when you interact with us through our Services. It also applies anywhere it is linked. It does not apply to non- Willow Wood Financial websites and mobile applications that may link to the Services or be linked to or from the Services; please review the privacy policies on those websites and applications directly to understand their privacy practices.

Information We Collect 

Information you give us

Some of the Services may include features or services that permit you to enter contact information and other information about you. We collect and store any information you enter on our Services. This includes:

• – Contact and demographic information when completing forms or registering to use our Services.
• – Payment information and associated contact information when engaging in a transaction on our site.
• – Email address information when subscribing to our email newsletters.
• – Any information or data you provide by interacting in our online forums and chatrooms, or by commenting on content posted on our Services. Please note that these comments are also visible to other users of our Services.
• – Information you provide when you complete a survey administered by us or a service provider acting on our behalf.
• – Information you provide when you participate in a contest or sweepstakes that we offer.
• – If you contact us, we may keep a record of that correspondence and any contact information provided.
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Information We Collect Automatically

When you interact with the Services, certain information about your use of our Services is collected automatically. This includes:

• – Details of your visits to our site and information generated in the course of the use of our site (including the timing, frequency, and pattern of service use) including, but not limited to, traffic data, location data, weblogs and other communication data, the resources that you access, and how you reached our site.
• – Details regarding the device you use to access our Services, including, but not limited to, your IP address, operating system, and browser type.
• – Information about how you interact with our ads and newsletters, including whether you open or click links in any correspondence.
• – Information that you make available to us on a social media platform (such as by clicking on a social media icon linked from our Services), including your account ID or username and other information included in your posts.

Much of this information is collected through cookies, web beacons, and other tracking technologies, as well as through your web browser or device. Willow Wood Financial relies on partners to provide many features of our sites and Services using data about your use of Willow Wood Financial and other sites.

Below is a list of these partners with links to more information about their use of your data and how to exercise your options regarding tracking.

Most web browsers automatically accept cookies but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your browser to decline cookies, some features of the Services may not be available, work, or work as designed. You may also be able to opt out of or block tracking by interacting directly with the other companies who conduct tracking through our Services.

How We Use and Protect Your Information

We may use the information we collect from you for the following purposes:

• – To provide you with our products and services, including to take steps to enter into a contract for sale or for services, process payments, fulfill orders, and send service communications.
• – To enable additional features on our Services and to provide you with a personalized service.
• – Create custom audiences on social media sites.
• – To provide you with the best service and improve and grow our business, including by understanding our customer base and purchasing trends and understanding the effectiveness of our marketing.
• – To understand how our Services are being used, track site performance, and make improvements.
• – To detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal, and to comply with legal requirements regarding the provision of products and services.

How We Secure the Information We Collect From or About You

We use a combination of physical, technical, and administrative safeguards to protect the information we collect through the Services. While we use these precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.

How We Share Your Information

• – Service Providers: We engage the following types of vendors to perform functions on our behalf such as: billing and collection providers; auditing and accounting firms; professional services consultants; providers of analytics services; security vendors; and IT vendors. We also share information from applications with other funding companies to assist you in obtaining business funding, but only with your consent.
• – Social Media Platforms: Where you choose to interact with us through social media, your interaction with these programs typically allows the social media company to collect some information about you through digital cookies they place on your device and other tracking mechanisms they place on your device. In some cases, the social media company may recognize you through its digital cookies even when you do not interact with their application. Please visit the social media companies’ respective privacy policies to better understand their data collection practices and the controls they make available to you.
• – Companies involved in advertising: We partner with companies that assist us in advertising about our Services to others who may be interested in the Services. These companies may use tracking technologies on our website to collect or receive information from the Services and elsewhere on the internet and use that information to provide measurement services and target ads. 
• – Corporate Affiliates: We share data with other members of our group of companies.
• – Business Partners: We share data with Affiliates and business partners who may sell services of interest to you.

Additional Information About our Data Collection and Sharing Practices

Sharing of Aggregated Data

We may share aggregated or de-identified data at our discretion, including with marketing agencies, media agencies and analytics providers. These other companies will not be able to relate this data to identifiable individuals.

Combination of Information

We may combine information from the Services together and with other information we obtain from our business records. 

Data Collected From You About Others

If you decide to refer others to Willow Wood Financial we will collect your and the other person’s names, email addresses, and/or phone numbers in order to send an email or text message and follow up with the other person. You agree that you will obtain the other person’s consent to this before giving us their contact information. You also agree that you will not send us the contact information of a minor. We will inform any other person you invite that you gave us his or her information in the invitation email.

Change of Ownership or Corporate Organization

We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Policy.

Cross-border Transfer of Data

If you use our Services outside of the United States, you understand that we may collect, process, and store your information in the United States and other countries. The laws in the U.S. regarding information may be different from the laws of your state or country. Any such transfers will comply with safeguards as required by relevant law. By using the Services, you consent to the collection, international transfer, storage, and processing of your data.

Your Options and Rights Regarding Your Information

Please log in to your Willow Wood Financial account to update your contact information.

If at any time you would like to unsubscribe from receiving future emails, you can click the unsubscribe link at the bottom of any email newsletter, or email us at [email protected] and we will promptly remove you from all correspondence.

You can learn more about ad serving companies and the options available to limit their collection and use of your information by visiting the websites for the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Digital Advertising Initiative. Similarly, you can learn about your options to opt out of mobile app tracking by certain advertising networks through your device settings and by resetting the advertiser ID on your Apple or Android device.

Please note that opting out of advertising networks services does not mean that you will not receive advertising while using our Services or on other websites, nor will it prevent the receipt of interest-based advertising from other companies that do not participate in these programs. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms. If you delete your cookies, you may also delete your opt-out preferences.

Your California Privacy Rights

Persons with disabilities may obtain this notice in alternative format upon request by contacting us at [email protected] or calling (979) 383-2013.

California Shine the Light

Residents of the State of California have the right to request information from Willow Wood Financial regarding other companies to whom the company has disclosed certain categories of information during the preceding year for those companies’ direct marketing purposes. If you are a California resident and would like to make such a request, please email [email protected] or write to us at Willow Wood Financial 50 Iron Point Circle, Suite 140, Folsom, CA 95630.

California Consumer Privacy Act

The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to know/access, delete, and limit sharing of Personal Information. The CCPA defines “Personal Information” as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.

To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.

Right to Notice at Collection Regarding the Categories of Personal Information Collected

You have the right to receive notice of the categories of Personal Information we collect, and the purposes for which those categories of Personal Information will be used. This notice should be provided at or before the time of collection. The categories we use to describe the information are those enumerated in the CCPA.

• Personal Identifiers:

o    We collect your name, phone number, and email address and contact address when you create an account or complete a transaction. If you choose to create an account, you will also be asked to create a username, and we will assign one or more unique identifiers to your profile. We use this information to provide the Services, respond to your requests, and send information and advertisements to you.

o    We collect your social media handle and basic account information when you interact with our Services through social media.

o    We collect a unique numerical identifier, assigned to you by a first-party cookie, automatically when you use our Services in order to identify you, provide the Services, keep you logged in to the Services, prevent fraud, and provide you with targeted information and offers.

o    We collect payment information when you provide it to us, which may include your bank account number, when you complete a transaction. You have the option to store this information to your account or set up a recurring transaction. We use this information to streamline and facilitate payments and transactions.

o    We collect your Social Security number and Driver’s License number. We do not collect your Passport number. We use this information to identify you, authenticate and collate information about you, prevent fraud, and conduct background checks or other screening activities.

o    We do not collect any medical information or health information about you.

o    We collect your IP address automatically when you use our Services. We use this information to identify you, gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and serve targeted advertisements based on your online activities.

o    We collect your Device ID automatically when you use our Services. We use this information to monitor your use and the effectiveness of our Services, to identify you, and to provide you with targeted information and offers.

• – Protected Classifications: We collect your age in order to comply with laws that restrict collection and disclosure of personal information belonging to minors. We also collect your gender. We use this information to measure the appeal and effectiveness of our Services with members of particular groups, and to provide you with targeted information, advertisements and offers.
• – Commercial Information: When you engage in transactions with us, we create records of goods or services purchased or considered, as well as purchasing or consuming histories or tendencies. We use this information to measure the effectiveness of our Services and to provide you with targeted information, advertisements and offers. We may also collect reviews you post about our services on third-party websites.
• – Biometric Information: We do not collect information about your physiological, biological, or behavioral characteristics.
• – Internet or Other Electronic Network Activity Information: We collect information about your browsing history, search history, and interactions with websites and/or applications automatically when you utilize our Services. We use this information to gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and to serve targeted advertisements based on your online activities. We do not collect information about your information regarding your interaction with advertisements automatically when you utilize our Services.
• – Geolocation Data: As described above, we collect your IP address automatically when you use our Services. We may be able to determine your general location based on the IP address. We do not collect your precise location (e.g., your GPS coordinates).
• – Audio, electronic, visual, thermal, olfactory, or similar information: If you contact us via phone, we may record the call. We will notify you if a call is being recorded at the beginning of the call. We do not collect your image or any thermal, olfactory, or similar information. We use this information to monitor our customer service, maintain the security of our systems and physical locations, and train employees.
• – Professional or employment-related information: We collect information about your current employer and your employment history. We use this information to conduct background and other screening activities, and to promote our Services to others.
• – Education information: We collect information about the institutions you have attended and the level of education you have attained. We use this information to conduct background and other screening activities, and to promote our Services to others.
• – Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We do not analyze your actual or likely preferences.

We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected.

We may share any of the above-listed information with Service Providers, which are companies that we engage for business purposes to conduct activities on our behalf. Service Providers are restricted from using Personal Information for any purpose that is not related to our engagement. The categories of Service Providers with whom we share information and the services they provide are described in our Privacy Policy above in the section titled “How We Share Your Information.”

We also sell some information to third parties, as described below. To opt out of the sale of your information visit our “Do Not Sell My Personal Information page”. Our full Privacy Policy can be found at https://www.willowwoodfin.com/privacy-policy.

Right to Know/Access Information

You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. You may submit such a request as described below. To protect our customers’ Personal Information, we are required to verify your identify before we can act on your request.

Right to Request Deletion of Information

You have the right to request in certain circumstances that we delete Personal Information that we have collected directly from you. You may submit such a request as described below. To protect our customers’ Personal Information, we are required to verify your identify before we can act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

How to Submit a Request

You may submit a request to exercise your rights to know/access or delete your Personal Information through one of two means:

(1)   By filling out a Consumer Data Request Form available here.

(2)   By calling us at (979) 383-2013.

Verification Procedures

In order to process your request to know/access or delete Personal Information we collect, disclose, or sell, we must verify your request. We do this by:

Asking you to:

• – Provide personal identifiers we can match against information we may have collected from you previously; and
• – Confirm your request using the email or telephone account stated in the request.

Authorized Agent

You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf. We require that you and the individual complete notarized affidavits in order to verify the identity of the authorized agent and confirm that you have authorized them to act on your behalf. Parents of minor children may submit a birth of the child certificate in lieu of an affidavit, in order to make requests on the child’s behalf. Please see our required affidavits here.

Right to Opt Out of Sale of Personal Information to Third Parties

You have the right to opt out of any sale of your Personal Information by Willow Wood Financial to third parties.

We sell information to third parties. To “sell” information means to disclose it to a company for monetary or other benefit. A company may be considered a third party either because the purpose of sharing is not an enumerated business purpose under California law, or because our contract does not restrict them from using Personal Information for other purposes.

You have the right to opt out of any sale of your Personal Information by Willow Wood Financial to third parties.

Changes to This Policy

We may make changes to this Policy from time to time. We will post any changes here, and such changes will become effective when they are posted. Your continued use of our Services following the posting of any changes will mean you accept those changes.

For questions about our privacy practices, contact us at:

Willow Wood Financial

50 Iron Point Circle, Suite 140, Folsom, CA 95630

Email: [email protected]