Effective Date: January 1, 2024
We may modify this Policy at any time. All changes will be effective immediately upon posting to the Site. Material changes will be conspicuously posted on the Site or otherwise communicated to you.
1. Information We Collect
We may collect information that can be used to identify you (“Personal Information”) when you use our Site or make use of any of the services available through our Site including investment and advisory services (collectively, “Services”). This Policy covers any Personal Information collected from you through this Site or offline as it relates to your use of our Services. The Personal Information we collect falls into three categories: (a) information you provide to us; (b) information we collect through automated methods when you use our Services; and (c) information we collect from other sources (as further detailed below).
We collect several types of Personal Information from and about users of our Services. Information we collect may include:
- Contact Information, such as your name, address, zip code, mobile phone number and email address.
- Demographic information, such as your date of birth.
- Account information, if you set up an account, such as your username and password and account transactions.
- Transaction and anticipated transaction information related to your account, such as your investment history, investment frequency, investment preferences, and your signature.
- Financial information, such as the name of your financial institution, account summaries and balances, account performance, your bank account, and routing number.
- Applicant information, if you apply for a job with us.
- Electronic information such as your internet browsing history, search data, browser type, IP address, device identifier, mobile advertising identifier, internet service provider, and analytics related to your interactions on the Site.
- Interactions that you have with us related to your use of the Services, such as emails, call recordings, and surveys that you respond to.
- General geolocation information, such as your IP address and approximate location data obtained through Wi-Fi, WLAN or Bluetooth access points.
You can visit the Site without submitting Personal Information. However, Personal Information is required to use certain Services, for example, to create an online account, contact us via email or phone (where we may retain your message’s content and our response), receive or request data from us (e.g., donation information or newsletters), and respond to communications from us. In such circumstances, we may be unable to provide you with our Services unless you provide your Personal Information.
Information You Provide to Us
We collect Personal Information that you provide directly to us. If you elect to provide data that personally identifies you, we will collect, use, and disclose such Personal Information pursuant to this Policy and applicable law. This may occur in the following ways:
Online Accounts. To create an online account, you must submit your name and email address, and create a password. This data is used to populate a profile within your account.
Online Giving and Payment Data. When you register for online giving, we use a PCI-compliant payment processor to help us facilitate payment. WatersEdge does not receive your credit card, debit card or other financial information when you make a payment- such information is provided directly to our payment processor. However, WatersEdge does receive information about your payment and your contact information (e.g. name, email address, mailing address, phone number). WatersEdge will keep a record of your transactions.
Applying to Work with WatersEdge. To submit job application materials online to work with WatersEdge on our Careers page, you will be prompted to provide us with certain information to complete an application. We will only use those job application materials to evaluate your qualifications to work with WatersEdge and its affiliates.
Marketing Communications & Email Opt-Out. If we receive your contact information, such as your email address or home address, we may use this information to send you promotional and other electronic and hardcopy communications related to our Services. We may use third-parties or service providers to deliver communications to you. You may opt-out of such marketing emails by using the unsubscribe link in the email or contacting us at firstname.lastname@example.org with “Unsubscribe” in the subject line. To opt-out of other communications (e.g., postal marketing and telemarketing), please contact us as set forth below. Opting out of marketing communications does not opt you out of non-marketing communications, such as emails about your transactions or donations.
Business Contracts with Us. When a business contracts directly with us, we may collect the business contact information of those involved. The processing of any information provided in such a business context is governed by the contracts between that business and WatersEdge.
Feedback. When you provide comments or feedback about our Site, the content on the Site, or our Services (“Feedback“), we will not treat that Feedback as confidential, and we may use that Feedback for any purpose in our sole discretion so long as it does not personally identify you. Feedback will be used without attribution or compensation to you.
Data Automatically Collected
We may use automated technology to collect information when you use our Services online. This may include the following:
Account Activity. We may collect data about how you use (i) your online account, and (ii) the Site when you are logged into your account. We may combine data automatically collected from you with other Personal Information about you.
A Cookie can either be a “session” Cookie or a “persistent” Cookie. Session Cookies exist only for so long as you are visiting the applicable Site and are typically deleted when you exit your web browser. Persistent Cookies exist for a set period of time, for example, up to several months or years. Each time you visit a Site that has implemented a persistent Cookie, the persistent Cookie is renewed, and that Cookie will remain active until its predetermined expiration date. You can manually delete persistent Cookies through your browser settings.
Cookies may either be “first-party” or “third-party” Cookies. A first-party Cookie allows your web browser to talk to the actual Site that you are visiting (i.e. this Site). A third-party Cookie allows your web browser to talk to a third-party website, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider. We may not have control over how a third-party uses information collected through third-party Cookies.
Most browsers automatically accept cookies. You can disable this function by changing your browser settings but disabling cookies may impact your use and enjoyment of the Site. Not all features or functions of the Site may work properly if you disable Cookies. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Site.
The Cookies on our Site may collect information such as:
- IP addresses assigned to the computers and other devices you use;
- your internet service provider;
- device ID number;
- approximate geographic location;
- browser type;
- Site pages visited;
- websites you access before and after visiting the Site, and
- data related to how and when you use the Site.
Data from Other Sources
We may obtain Personal Information about individuals from various third-party companies, such as social media platforms, and public sources. We may combine this Personal Information with other Personal Information we have collected about you. This enhances our existing data about our users, improves our ability to contact you, and enhances our marketing capabilities. For more information about how we use social media, please see more below.
2. How We Use Your Information
We use Personal Information that we collect for the following purposes:
As Stated or Agreed to at the Point of Collection. We may use Personal Information for the business purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use Personal Information to respond to your questions, comments, or complaints. We may also use Personal Information as requested or consented to by you.
Service Fulfillment. We may use Personal Information to provide you Services or information you may have requested.
Administration. We use Personal Information for administrative purposes, such as managing your accounts, facilitating transactions, to inform our business strategies, and to understand the Site’s demographics and user preferences.
Site Management. We use Personal Information for Site management, such as troubleshooting problems, improving the content and functionality of the Site, statistical and other analyses of the Site, and to customize the Site to you and our users.
Business Analytics. We use Personal Information to perform consumer and operation research and to assess the effectiveness of our online services, marketing, and advertising.
Accepting and Managing Donations. We use Personal Information to accept, process and solicit donations; administer and maintain accounts relating to donations; facilitate fundraising; and to communicate with donors and prospective donors concerning our program.
Advertising and Communications. We may use Personal Information to send you promotions or to perform targeted advertising, to notify you of new services or programs, to notify you of new features of our Site, to notify you of changes to our Terms or this Policy, and for other similar communications.
To Protect Our Rights. We may use Personal Information to protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our Site, or to other users of the Site. We may also use Personal Information to seek business, financial or legal advice, and to respond to other legal requests.
Additional Uses of Personal Information Collected by Automatic Technologies
In addition to those purposes described elsewhere in this Policy, we also use information gathered via Cookies to: (i) make our Site function properly; (ii) provide personalized experiences; (iii) tailor our interactions with you; (iv) help with our marketing efforts; (v) provide us with valuable data and statistics about the usage and effectiveness of our Site and to help us improve our Site; and (vii) help us improve our Services.
Google Analytics. We use Google Analytics to collect and process information about your use of the Site. Google sets cookies on your browser or device, and then your web browser will automatically send information to Google. Google uses this information to provide us with reports that we use to better understand and measure how users interact with our Site.
The Site also uses Google Tags, which allow the Site to use a variety of Google products and services, such as analytics and conversion tracking.
Online Behavioral Advertising. We use third parties and/or service providers to provide interest-based advertising services. These services may serve advertisements on our behalf that are customized based on predictions about your interests generated from your visits to websites (including the Site) over time and across different websites. The data collected may be associated with your Personal Information. These advertisements may appear on the Site and on other websites and may be sent to you via email.
To change your preferences with respect to certain online ads or to obtain more information about ad networks and online behavioral advertising, visit National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads. Opting-out of targeted advertising does not opt you out of all ads, just those targeted to you.
3. Retention of Personal Information
We will keep Personal Information for the period necessary to fulfil the purposes described in this Policy or provide you with the Services, unless a longer retention period is permitted or required by law.
4. How We Disclose Your Personal Information
We may disclose Personal Information to the following categories of parties, in compliance with applicable laws:
Employees and Affiliates. We may disclose Personal Information with our employees and affiliates who have a need to know the information for our business purposes related to providing our Services.
Third Parties Service Providers. We may disclose Personal Information to third parties that provide services for us. For example, we may disclose Personal Information to vendors to help us host and manage the Site; provide targeted advertising and other marketing; improve the content and functionality of the Site; perform data analysis and statistical analysis; troubleshoot problems with the Site; provide payment processing services; and support or provide the security of the Site.
Government Officials & Law Enforcement. We may cooperate with law enforcement and other governmental agencies, and may disclose Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, WatersEdge or any other party.
Professional Advisors. We may disclose Personal Information with our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to WatersEdge.
Change in Ownership. In the event WatersEdge is the subject of a change of control or in the event the Site changes ownership, in whole or in part, or in the event of a bankruptcy, receivership or a similar transaction, we may provide Personal Information to the subsequent owner(s), including with respect to due diligence related to the foregoing.
Other. We may disclose Personal Information with third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).
5. Children’s Information
The Site is not directed at children under 18 years of age. We do not knowingly collect, sell, use, or disclose Personal Information from children under 18. If we have actual knowledge that any Personal Information we collect has been provided by a child under the age of 18, we will make reasonable efforts to delete that information. If a parent or legal guardian learns that their child provided us with Personal Information without their consent, please contact us and we will make reasonable efforts to delete such Personal Information.
6. Data Security
We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. If a breach of your Personal Information occurs, we will notify you of the breach if and as required under applicable law.
You understand that no data transmission over the internet or electronic device can be guaranteed to be 100% secure. While we strive to protect Personal Information, we do not guarantee the security of Personal Information and you provide Personal Information at your own risk.
7. Social Media
We are active on social media, including Facebook, LinkedIn, and Vimeo (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Site and our Social Media pages any comments or content that you post on our Social Media pages.
Your use of Social Media is governed by the privacy policies and terms of the providers that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.
8. Access from Outside the United States
Our Services are operated and located in the United States and are intended for customers located in the United States only. If you access the Site from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required by in other jurisdictions, and if you access our Site or Services from outside the United States, you do so at your own risk.
9. Third-Party Websites
10. Contact Us
If you have questions or concerns regarding this Policy, contact us at:
3800 North May Avenue
Oklahoma City, OK 73112