California Consumer Privacy Disclosure: Individuals and Website Visitors

Last Updated On: September 29, 2024

RWM provides this Privacy Disclosure (“Disclosure”) to explain how we handle Personal Information collected through our websites, social media accounts, online advertisements, and communications (collectively referred to as our “Platforms”), as well as through mail, phone interactions, in-person meetings and events, and other online and offline methods.

**Changes:** We may update this Disclosure periodically. Any updated Disclosure will take effect when it is posted. We encourage you to review this Disclosure regularly for any updates. If required by law, we will notify you directly of any changes.

  • We collect Personal Information about you from the following sources:

    A. Directly from You: We may gather Personal Information that you provide directly, such as when you contact us through our Platforms, engage with us in person, sign up for offers or newsletters, or communicate with us in other ways.

    B. Automatically Collected Data and Tracking Technologies: We may automatically collect information or make inferences about you through cookies and other tracking technologies when you interact with our Platforms. This can include data about your usage and interactions with our Platforms, device information, and internet usage details. For more information, please refer to “Section 5 – Cookies and Other Tracking Technologies.”

    C. Service Providers: We may receive information from service providers who collect data on our behalf.

    D. Affiliates and Subsidiaries: We may obtain information from our affiliates and subsidiaries.

    E. Rwamashongye Wealth Management Agent: We may gather information from Rwamashongye Wealth Management Agent, such as agents and brokers.

    F. Third Parties: We may receive information from third parties, including commercial business partners, data brokers, social media companies, or other independent entities that interact with us.

    G. Publicly Available Sources: We may collect Personal Information from publicly available sources, such as public profiles and websites.

    We may combine information from these various sources, including third-party sources, and use or disclose it for the purposes identified below.

  • We may collect the following types of Personal Information about you:

    A. Identifiers: This includes your name, email address, physical address, telephone number, and device identifiers.

    B. Records About You: Such as medical or health information, investment details, estimated income, and other information obtained from commercial data partners.

    C. Protected Class and Demographic Information: This includes age (including birthdates), gender, and veteran status.

    D. Commercial Information: This encompasses records of personal property, products or services purchased, obtained, or considered, as well as other purchasing or consumption histories and tendencies.

    E. Internet or Electronic Network Activity Information: This pertains to you, your device, and how you interact with our Platforms. Data elements may include browsing history, search history, preferences (including marketing and purchasing preferences), account settings (such as default preferences), operating system, browser type, and other details about your interactions with our Platforms (like pages viewed).

    F. Non-Precise Geolocation Data: Such as your location derived from your IP address.

    G. Audio, Visual, or Other Sensory Information: This includes photographs and audio/video recordings.

    H. Professional or Employment-Related Information: Such as job title, organization, and other professional details.

    I. Education Information.

    J. Inferences: These are drawn from any of the information we collect regarding your preferences or behavior.

    K. Sensitive Personal Information: This includes health information obtained from commercial data partners or inferred from your interactions with our Platforms.

  • We may use Personal Information for the following purposes:

    A. Internal Business Operations: This includes managing our Platforms and tailoring content; maintaining internal records such as accounting and document management; enforcing our policies; generating management reports; conducting audits; administering IT for our network and technologies; and overseeing IT security management.

    B. Research and Business Improvement: We may use Personal Information to verify, maintain, or enhance the quality of our services (including our Platforms); assess the effectiveness of our advertising and marketing efforts; and troubleshoot and resolve issues with our systems, networks, and equipment.

    C. Legal, Safety, and Security: We may use your information to comply with legal obligations and reporting requirements; investigate claims against the Company or its personnel; establish, exercise, or defend legal claims; safeguard the safety, property, or rights of the Company, our customers, and third parties; detect, prevent, and respond to security incidents; and protect against malicious, deceptive, fraudulent, or illegal activities.

    D. Corporate Transactions: In connection with any corporate transactions, such as acquiring, selling, or transferring all or part of our business or assets.

    E. Marketing and Targeted Advertising: We may use your Personal Information to market our business and that of our affiliates, business partners, or third parties (for this purpose, “we” or “our” includes these entities). For instance, we might personalize advertising for you on our Platforms or third-party sites, analyze interactions with our emails or viewed website sections, develop target audiences for our products and services, or send you newsletters, surveys, promotions, or information about events and webinars. You can opt out of our email marketing by using the unsubscribe link in the email or by contacting us using the information in the Contact Information section below.

    We may also utilize anonymized, de-identified, or aggregated information for any purpose permitted by law.

  • We may share your personal information with third parties, as outlined in the categories below. While we do not "sell" your personal information for monetary compensation, we do engage in practices that could be classified as a "sale" (disclosing personal information to third parties for value) or "sharing" (disclosing personal information for targeted advertising), as defined by the CCPA. We do not intentionally sell or share personal information about minors.

    The categories of recipients mentioned in the chart above refer to:

    A. Affiliates and Subsidiaries: This includes parent companies, corporate affiliates, subsidiaries, business units, and other entities under common ownership.

    B. Professional Consultants: These are specialists like accountants, lawyers, financial advisors, and audit firms.

    C. Vendors: Necessary parties involved in fulfilling a transaction you request, such as shipping companies.

    D. Law Enforcement and Government Agencies: This includes recipients for legal, security, or safety purposes, such as sharing information to comply with laws, enforce our Terms of Use and other agreements, and protect the safety, property, or rights of the Company, our customers, or third parties.

    E. Corporate Transaction Entities: This involves other organizations in the context of a corporate transaction, such as if we or our assets are acquired by another entity, including through bankruptcy or other corporate changes.

    F. Entities with Your Consent: Any other parties to whom you have agreed to disclose your information.

  • Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose

    • Affiliates and subsidiaries
    • Professional consultants
    • Vendors necessary to complete transactions you request
    • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
    • Other entities in connection with a corporate transaction
    • Entities to which you have consented to the disclosure

    Categories of Third Parties to Whom Personal Information is Sold* or Shared*

    • Advertisers, ad platforms and networks, and social media platforms
    • Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Tracking Technologies)
    • Commercial data partners to whom we make information available for their own marketing purposes
    • Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services

  • Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose

    • Affiliates and subsidiaries
    • Professional consultants
    • Vendors necessary to complete transactions you request
    • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
    • Other entities in connection with a corporate transaction
    • Entities to which you have consented to the disclosure

    Categories of Third Parties to Whom Personal Information is Sold* or Shared*

    • Not sold or shared


  • Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose

    • Affiliates and subsidiaries
    • Professional consultants
    • Vendors necessary to complete transactions you request
    • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
    • Other entities in connection with a corporate transaction
    • Entities to which you have consented to the disclosure

    Categories of Third Parties to Whom Personal Information is Sold* or Shared*

    • Not sold or shared

  • Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose

    • Affiliates and subsidiaries
    • Professional consultants
    • Vendors necessary to complete transactions you request
    • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
    • Other entities in connection with a corporate transaction
    • Entities to which you have consented to the disclosure

    Categories of Third Parties to Whom Personal Information is Sold* or Shared*

    • Advertisers, ad platforms and networks, and social media platforms
    • Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Tracking Technologies)
    • Commercial data partners to whom we make information available for their own marketing purposes
    • Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services

  • Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose

    • Affiliates and subsidiaries
    • Professional consultants
    • Vendors necessary to complete transactions you request
    • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
    • Other entities in connection with a corporate transaction
    • Entities to which you have consented to the disclosure

    Categories of Third Parties to Whom Personal Information is Sold* or Shared*

    • Advertisers, ad platforms and networks, and social media platforms
    • Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Tracking Technologies)
    • Commercial data partners to whom we make information available for their own marketing purposes
    • Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services

  • Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose

    • Affiliates and subsidiaries
    • Professional consultants
    • Vendors necessary to complete transactions you request
    • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
    • Other entities in connection with a corporate transaction
    • Entities to which you have consented to the disclosure

    Categories of Third Parties to Whom Personal Information is Sold* or Shared*

    • Advertisers, ad platforms and networks, and social media platforms
    • Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Tracking Technologies)
    • Commercial data partners to whom we make information available for their own marketing purposes
    • Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services

  • Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose

    • Affiliates and subsidiaries
    • Professional consultants
    • Vendors necessary to complete transactions you request
    • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
    • Other entities in connection with a corporate transaction
    • Entities to which you have consented to the disclosure

    Categories of Third Parties to Whom Personal Information is Sold* or Shared*

    Not sold or shared

  • Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose

    • Affiliates and subsidiaries
    • Professional consultants
    • Vendors necessary to complete transactions you request
    • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
    • Other entities in connection with a corporate transaction
    • Entities to which you have consented to the disclosure

    Categories of Third Parties to Whom Personal Information is Sold* or Shared*

    Not sold or shared

  • Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose
    • Affiliates and subsidiaries
    • Professional consultants
    • Vendors necessary to complete transactions you request
    • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
    • Other entities in connection with a corporate transaction
    • Entities to which you have consented to the disclosure

    Categories of Third Parties to Whom Personal Information is Sold* or Shared*

    Not sold or shared

  • Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose

    • Affiliates and subsidiaries
    • Professional consultants
    • Vendors necessary to complete transactions you request
    • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
    • Other entities in connection with a corporate transaction
    • Entities to which you have consented to the disclosure

    Categories of Third Parties to Whom Personal Information is Sold* or Shared*

    • Advertisers, ad platforms and networks, and social media platforms
    • Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Tracking Technologies)
    • Commercial data partners to whom we make information available for their own marketing purposes
    • Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services

  • Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose

    • Affiliates and subsidiaries
    • Professional consultants
    • Vendors necessary to complete transactions you request
    • Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
    • Other entities in connection with a corporate transaction
    • Entities to which you have consented to the disclosure

    Categories of Third Parties to Whom Personal Information is Sold* or Shared*

    Not sold or shared

  • Our Platforms (and authorized third parties) use cookies and other tracking technologies to collect information about you, your device, and how you interact with our Platforms. This section contains additional information about:

    • The types of tracking technologies we use and the purposes for which we use them

    • The types of information we collect using these technologies

    • How we disclose or make information available to others

    • Choices you may have regarding these technologies

    A. Types of cookies and tracking technologies we use

    Our Platforms and the third parties that we authorize may use the following tracking technologies:

    • Cookies, which are a type of technology that install a small amount of information on a user's computer or other device when they visit a website. Some cookies exist only during a single session and some are persistent over multiple sessions over time.

    • Pixels, web beacons, and tags, which are types of code or transparent graphics that contain a unique identifier. In addition to the uses described in Section 5.B below, these technologies provide analytical information about the user experience and help us customize our marketing activities. In contrast to cookies, which are stored on a user's computer hard drive, pixels, web beacons, and tags are embedded invisibly on web pages.

    • Session replay tools, which record your interactions with our Platforms, such as how you move throughout our Platforms and engage with our webforms. In addition to the uses described in Section 5.B below, this information helps us improve our Platforms and identify and fix technical issues visitors may be having with our Platforms.

    • Embedded scripts and SDKs, which allow us to build and integrate custom apps and experiences, some of which may be developed by a third party.

    B. Purposes for Using These Technologies

    We and authorized third parties use these technologies for purposes including:

    • Personalization, such as remembering user preferences, login details and browsing behavior; tracking your activity across online properties and Platforms over time to better understand your preferences and interests; and personalizing your online content;

    • Improving performance, such as maintaining and improving the performance of our Platforms;

    • Analytics, such as analyzing how our Platforms are used. For example, we use Google Analytics to help us improve our Platforms, performance and user experiences. Google Analytics may use cookies and other tracking technologies to perform their services. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners; and

    • Advertising, such as providing you with offers that may be of interest to you; conducting targeted advertising to you on our Platforms and those of third parties; and measuring the effectiveness of our communications with you and advertising campaigns, including identifying how and when you engage with our communications.

    C. Personal Information Collected

    These tracking technologies collect data about you and your device, such as your IP address, cookie ID, device ID, AdID, operating system, browser used, browser history, search history, and information about how you interact with our Platforms (such as pages on our Platforms that you have viewed, including your specific mouse movements, page clicks, and other session replay information).

    D. Disclosures of Personal Information

    We may disclose information to third parties or allow third parties to directly collect information using these technologies on our Platforms such as social media companies, advertising networks, companies that facilitate session replay recordings and analysis, companies that provide analytics including ad tracking and reporting, security providers, and others that help us operate our business and Platforms.

    E. Your Choices

    Some of the third parties we work with participate with the Digital Advertising Alliance ("DAA") and Network Advertising Initiative ("NAI"). The DAA and NAI provide mechanisms for you to opt out of interest-based advertising performed by participating members at http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/.

    You can also refuse or delete cookies using your browser settings. If you refuse or delete cookies, some of our Platforms’ functionality may be impaired. Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your cookies, you may need to repeat this process for each computer, device, or browser. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from us or our agents or representatives.

    Some browsers have incorporated Do Not Track (“DNT”) preferences. We do not currently honor such signals.

  • Our Information Governance and Records Management Program establishes and maintains company policies and procedures governing the creation, retention, storage, and disposition of corporate records and information, provided that such information to be deleted or destroyed is not subject to regulatory requirement to retain it or a legal hold. We retain corporate records for the minimum time period required by law or regulation and/or for a longer period of time consistent with business needs. We determine retention periods for corporate record information using both legal/regulatory citations and business requirements. Citations for retention periods are regularly reviewed by outside counsel and updated as necessary. CCPA rights request records are subject to a two year retention period as required by California law.

  • California Consumers may have certain rights, subject to legal limitations, regarding the collection, use, and sharing of Personal Information under the CCPA, such as:

    • Right to Know. You may request information about the categories of Personal Information we have collected about you; the categories of sources from which we collected the Personal Information; the purposes for collecting, selling, or sharing the Personal Information; and to whom we have disclosed your Personal Information and why. You may also request the specific pieces of Personal Information we have collected about you.

    • Right to Delete. You may request that we delete Personal Information that we have collected from you.

    • Right to Correct. You may request that we correct inaccurate Personal Information that we maintain about you.

    • Right to Limit Sensitive Personal Information Processing. We generally only use Sensitive Personal Information that is subject to the CCPA for the following purposes: (i) performing services or providing goods reasonably expected by an average consumer; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) for short-term, transient use, including non-personalized advertising; (vi) performing or providing internal business services; (vii) verifying or maintaining the quality or safety of a service or device; or (viii) for purposes that do not infer characteristics about you. In limited circumstances, you may have the right to limit our processing of your Sensitive Personal Information.

    • Right to Opt Out of Sale/Sharing. You may request to opt out from the sale or sharing of your Personal Information. We do not knowingly sell or share any Personal Information of minors under the age of 16.

    You may exercise a Right to Know, Right to Delete, Right to Correct, and Right to Limit Sensitive Personal Information Processing via our webform.

    You may exercise your preferences and learn about the Right to Opt-Out of Sale/Sharing by visiting our Preference Hub. To the extent required by law, we will honor opt-out preference signals sent in a format commonly used and recognized by businesses, such as an HTTP header field or JavaScript object. We will process opt-out preference signals at the browser level.

    If you need assistance submitting a request or have questions regarding this Disclosure or how the Company uses your Personal Information, please contact us at 1-360-258-0555 or email us at andrew@rwamashongyewealthmanagement.com

8. Statistical Information About Responses to Requests

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9. Contact Information

If you need assistance submitting a request or have questions regarding this Privacy Disclosure or how RWM uses your Personal Information, please contact us at 360-258-0555 or email us at andrew@rwamashongyewealthmangement.com