Privacy Policy - Wall Street Oasis

Privacy Policy - Wall Street Oasis

IB Oasis Corp. ("WSO" or "Wall Street Oasis") is committed to protecting your privacy. This Privacy Policy describes how we collect, use and share data, and what choices you have with respect to your data. We have updated this version of our Privacy Policy to reflect changes in data protection law.

# Applicability of the Privacy Policy

This Privacy Policy applies to www.wallstreetoasis.com, our mobile applications, as well as our other services, offerings, and other interactions (e.g., customer service inquiries, etc.) you may have with us (together with our Site, collectively referred to as our “Services”). If you do not agree with the data practices described in this Privacy Policy, you should not use our Services.

This Privacy Policy does not apply to any third party applications or software that integrate with the Services through our Site (“Third Party Services”), or any other third party products, services or businesses.

# Mobile Communications & SMS Terms

SMS Data Collection

When you provide your phone number through our website forms, application forms, account registration, or other enrollment processes, we collect and store your phone number for the purpose of sending SMS communications related to your application, admissions reminders, student support, accountability check-ins, interview scheduling, and important program updates.

SMS messages are sent only to users who have provided prior express consent to receive SMS communications from Wall Street Oasis.

We use collected phone numbers solely to deliver SMS messages related to:

• Application updates
• Admissions reminders
• Interview confirmations
• Student support communications
• Accountability check-ins
• Important program notifications

Message frequency varies. You may receive up to 4 messages per month depending on your activity and enrollment status.

Message and data rates may apply according to your mobile carrier plan.

You may opt out of SMS communications at any time by replying STOP to any message received from us. A confirmation message will be sent to confirm your unsubscribe request.

For assistance, reply HELP or contact us at [email protected].

Your consent to receive SMS messages is not a condition of purchase.

Mobile information, including SMS opt-in data, consent records, and phone numbers, will not be shared, sold, rented, leased, transferred, or disclosed to any third parties or affiliates for marketing or promotional purposes.

All categories of personal data exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

SMS messages are sent solely by Wall Street Oasis.

# Information We Collect and Receive

We collect personal information about you in the following ways:

## Categories of Data Subjects

We process personal information relating to the following categories of individuals:

• Registered WSO forum users
• Website and mobile application visitors
• Applicants and prospective students who have expressed interest in or applied to our programs
• WSO Academy students and alumni
• Course and session subscribers and customers
• Program participants, including mentees and mentors
• Consultants and advisors who engage with us in connection with our Services

## Information you give us:

• Information that you may provide through the Services or otherwise communicate with us includes:
• Personal and Business Contact information, such as your first name, last name, postal address, email address, telephone number, job title, school data and employer name.
• Profile information, such as your username and password, picture, industry, interests and preferences
• Employment history and education information, such as resumes and curriculum vitae
• Content you post on our Site (text, images, photographs, messages, comments or any other kind of content that is not your e-mail address).
• Feedback and correspondence, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with our Site, receive customer support or otherwise correspond with us.
• Transaction information, such details about purchases you make through the Site, registrations you make through our Site, and billing details;
• Usage information, such as information about how you use our Site and interact with us.
• Marketing information, such as your preferences for receiving marketing communications and details about how you engage with them.
• Information from Social Networking Sites.

Our Site includes interfaces that allow you to connect with social networking sites (each a “SNS”). If you connect to a SNS through our Site you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Notice. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.

## Information we get from others:

We do not purchase data about you from other individuals or organizations.

We may combine other publicly available information, such as that provided by business networking sites and databases, information related to the organization for which you work and personal interests and skill sets, with the personal information that you provide to us through our Services.

We also may obtain information from those in the WSO such as our contractors and local representatives who have agreed to a relationship with us in order to deliver our Services.

## Information automatically collected:

We may automatically log information about you and your computer or mobile device when you access our Site. For example, we may log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site. We collect this information about you using cookies. Please refer to the Cookies and Similar Technologies section below for more details.

## Changes to your personal information:

It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us by updating your registration profile or emailing us at [email protected]. The data subject/s is/are solely liable for the accuracy of information provided by them and WSO claims no guarantee against the same.

# How We Use Your Information

## To provide our Services

If you have an account with us or use our Site, we use your personal information to:

• operate, maintain, administer and improve our Site;
• manage and communicate with you regarding your account, if you have one, including by sending you service announcements, technical notices, updates, security alerts, and support and administrative messages;
• process and manage requests you make through our Site, including to track and administer Services you have requested;
• better understand your needs and interests, and personalize your experience with the Site; and
• provide support and maintenance for the Site and our Services.

## To communicate with you

• If you request information from us, register on our Site, or participate in our surveys, promotions or events, we may send you updates, newsletters, surveys, offers, and other promotional materials that may be targeted based on your personal information as permitted by law.
• We also may, from time to time, contact you about a particular offering that may be of interest to you based on publicly available information or information obtained through WSO. You will have the ability to opt out of such communications.

## To comply with law

We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

## With your consent

• We may use or share your personal information with your consent, such as when you: consent to participate in additional surveys on gender and race/ethnicity (where legally permissible), let us post your testimonials or endorsements on our Sites, instruct us to take a specific action with respect to your personal information.

## To create aggregated or de-identified information

We may disclose or use aggregated or de-identified information for any purpose. For example, we may share aggregated or de-identified information with prospects, partners, or sponsors for business or research purposes, such as when we analyze and report on demographic trends to measure our objective of having healthy diversity ratios across our programs.

## For compliance, fraud prevention and safety

We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

# Data Sharing & Data Processors

We may share personal information with third parties that provide services on our behalf and support the operation and delivery of our Services. These third parties process personal information only for purposes related to the Services and in accordance with our instructions, where applicable.

## Categories of Third Parties We Share Data With

We may share personal information with the following categories of third parties:

• Hosting and Infrastructure Providers: To host our website, databases, applications, and related systems and to ensure availability, performance, and security.
• Email and Communications Service Providers: To send service-related communications, program updates, application-related correspondence, newsletters, and other communications to individuals who have expressed interest in or applied to our programs.
• Customer Relationship Management (CRM) Providers: To manage user interactions, applications, communications, and customer support activities.
• Analytics Providers: To understand how users interact with our Services and to improve functionality and performance.
• Advertising and Marketing Partners: To display advertising, measure campaign performance, and conduct retargeting activities where permitted by applicable law.
• Professional Service Providers and Consultants: Including mentors, advisors, and consultants who assist students in their professional development and high-finance career pursuits. These individuals may access personal information, including resumes and application materials, solely for purposes related to WSO programs and services.
• AI Moderation Services: Some of the content you provide may be run through AI services anonymously for the purpose of moderation and keeping users safe.

# Cookies and Similar Technologies

## What are cookies?

We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Site; and (2) third party cookies, which are served by service providers on our Site, and can be used by such service providers to recognise your computer or mobile device when it visits other websites. Where required by applicable law, we obtain your consent before placing non-essential cookies on your device.

## Cookies we use

Our Site uses the following types of cookies for the purposes set out below:

• Essential Cookies

These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

• Analytics and Performance Cookies

These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered may include the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.

We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here (https://policies.google.com/technologies/cookies) and about how Google protects your data here (https://policies.google.com/).

• Social Media Cookies

These cookies are used when you share information using a social media sharing button or “like” button on our Site, visit a specific page or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter. The social network will record that you have done this.

## Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org.

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site.

## Pixel tags

We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Site to track the actions of users on our Site. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Site, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ personal information.

## Do Not Track Signals

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

# Data Deletion & Your Choices

• You can request Data Deletion at any time. Access, Update, Correct or Delete Your Information. All account holders may review, update, correct or delete the personal information in their registration profile by logging into their account. You may also contact us at [email protected] to accomplish the foregoing or if you have additional requests or questions.

• Email communications. You may opt out of newsletters and marketing-related emails by following the unsubscribe instructions on a link at the bottom of each such email, or by contacting us at [email protected]. You may continue to receive service-related and other non-marketing emails.

• Withdrawing consent. If you gave us consent to use your personal information, but wish to update or delete it, please contact us at [email protected].

• Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the Services and may need to close your account. We will tell you what information you must provide to receive the Services by designating it as required in the Services or through other appropriate means.

We may modify this Privacy Policy from time to time, so we encourage you to review it frequently. If we make any material changes to the Privacy Policy, we will post a notice on our website prior to such change taking effect.

# Security

The security of your personal information is important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.

# Retention & User Notification

We will only retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances, we may anonymize your personal information (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you.

Without limiting the generality of the foregoing, we may retain different categories of personal information for different periods of time, depending on the nature of the information and the purposes for which it is processed. Indicative retention periods may include, for example:

• Account and profile information: Retained for the duration of an active account and for up to 12 months following account closure or a verified deletion request, unless a longer retention period is required or permitted by law.
• Applicant and program-related information (including resumes and application materials): Retained for up to 5 years following the conclusion of the relevant application or program, unless continued retention is necessary for legitimate business purposes or legal obligations.
• Mentor, consultant, and advisor information: Retained for the duration of the engagement and for up to 5 years thereafter, unless otherwise required by law.
• Customer support and correspondence: Retained to manage follow-up inquiries, quality assurance, and training.
• Transactional, billing, and payment-related records: Retained for up to 7 years, as required by applicable accounting, tax, or legal obligations.
• Marketing and communications preferences: Retained until you opt out of receiving such communications or request deletion. You have the right at any time to stop WSO from contacting you for marketing purposes or giving your data to other companies, Consultants, and/or Advisors we engage with.

In some circumstances, retention periods may be extended where required or permitted by law, including to comply with legal obligations, resolve disputes, or enforce our agreements. Where required by applicable law, we will take reasonable steps to notify users once their personal information has been deleted or anonymized in response to a verified request. Additionally, in the event of a personal data breach, we will take appropriate steps to investigate and remediate the incident and, where required by applicable law, notify affected individuals and relevant authorities.

# User Generated Content

We may make available on our Site, or link to, features that allow you to share information online (e.g., on message boards, in chat areas, in file uploads, through events, etc.). Please be aware that whenever you voluntarily disclose personal information online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use, storage or dissemination of such publicly-disclosed personal information. By posting personal information online in public forums, you may receive unsolicited messages from other parties.

# Other Sites and Services

Our Site may contain links to other websites and services. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.

# Children’s Privacy

Our Products and Services are not directed to children under the age of 13, and we do not intentionally gather personal information from visitors who are under the age of 13, without their parental or guardian’s consent. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at the contact information provided above. We will delete such information from our files as soon as reasonably practicable.

If we become aware that an applicant or user under the applicable age of consent (including under the age of 13, or under 16 where required by local law) has submitted personal information without appropriate consent, we will take reasonable steps to delete such information from our records as soon as reasonably practicable.

# For Users Outside the United States: International Data Transfers

WSO is headquartered in the United States. Your information, including personal information that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in your jurisdiction. We will take all reasonable steps to ensure that your data is treated securely and in accordance with this Policy.

References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European Union data protection legislation. We use the following safeguards if WSO transfers personal information originating from the European Union to other countries not deemed adequate under applicable data protection law:

## Controller

WSO is the controller of your personal information for purposes of European data protection legislation.

## Legal bases for processing

We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described below:

## Processing purpose

• Legal basis
• To provide our Services
• Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services.
• To communicate with you
• To create aggregated or de-identified information
• For compliance, fraud prevention and safety

These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

## To comply with law

Processing is necessary to comply with our legal obligations

## With your consent

Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at [email protected].

## Use for new purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

# WSO Academy Tools — Privacy Policy

Last updated: March 2026

This privacy policy explains how WSO Academy's networking tools ("Email Lookup" and "Auto-Draft Emails") collect, use, and protect your data.

## What data we access

When you connect your Gmail account through our Auto-Draft Emails tool, we request permission to create email drafts in your Gmail inbox. Specifically, we use the gmail.compose scope, which allows us to create draft emails only. We cannot and do not read your existing emails, send emails on your behalf, delete emails, or access any other Gmail data.

When you use our Email Lookup tool, we process the LinkedIn profile URL you submit and return publicly available professional contact information from third-party data providers.

## What data we store

Gmail authorization tokens: When you connect your Gmail, we store an encrypted authorization token that allows our system to create drafts in your inbox. We do not store your Gmail password.

Student profile information: Your name, school, year, major, and contact email — used to personalize your outreach email drafts.

Contact database: Professional contact information retrieved from third-party data providers (names, titles, companies, work emails) is stored to reduce redundant lookups and improve the service for all students.

## How we use your data

Your Gmail access is used solely to create personalized email drafts when your LinkedIn connection requests are accepted. We never read, send, modify, or delete any of your emails.

Your lookup history is used to provide analytics on networking activity, prevent abuse of the service.

We do not sell your data. We do not share your personal data with third parties for marketing purposes. We do not use your data for advertising.

## Third-party services

Our tools integrate with the following third-party services:

Google Gmail API: Used to create email drafts in your inbox. Subject to Google's API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy).

Apollo.io: Used to look up professional contact information from LinkedIn profile URLs.

HeyReach: Used to detect when your LinkedIn connection requests are accepted, triggering the auto-draft feature.

## Data security

Gmail authorization tokens are stored in a secured PostgreSQL database. Access to student data is restricted to authorized WSO Academy administrators. All communication between your browser and our servers is encrypted via HTTPS.

## Your rights and choices

Revoke Gmail access: You can disconnect your Gmail at any time by visiting your Google Account settings (myaccount.google.com) and removing "WSO Academy" from the list of third-party apps with access to your account. This immediately stops the auto-draft feature.

Request data deletion: Contact us at [email protected] to request deletion of your stored data.

Opt out: You are not required to connect your Gmail to use the Email Lookup tool. The Auto-Draft feature is entirely optional.

## Changes to this policy

We may update this privacy policy from time to time. Any changes will be reflected on this page with an updated date.

Contact

If you have questions about this privacy policy or how your data is handled, contact us at [email protected].

## Your Rights

European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

• Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails.
• Access. Provide you with information about our processing of your personal information and give you access to your personal information.
• Correct. Update or correct inaccuracies in your personal information.
• Delete. Delete your personal information.
• Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict. Restrict the processing of your personal information.
• Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
• Data portability. You have the right to request that WSO transfer the data that we have collected to another organisation, or directly to you, under certain conditions.

You can submit these requests by email to at [email protected]. We may request specific information from you to help us confirm your identity and process your request.

Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at [email protected] or submit a complaint to the data protection regulator in your jurisdiction.

## Cross-Border Data Transfer

Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on one of the following safeguards recognized by the European Commission as providing adequate protection for personal information, where required by EU data protection legislation:

Contracts approved by the European Commission which impose data protection obligations on the parties to the transfer. For further details, see European Commission Model contracts for the transfer of personal information to third countries.

# Advertising

This Site is affiliated with CMI Marketing, Inc., d/b/a CafeMedia ("CafeMedia") for the purposes of placing advertising on the Site, and CafeMedia will collect and use certain data for advertising purposes. To learn more about CafeMedia's data usage, click here: www.cafemedia.com/publisher-advertising-privacy-policy.

# Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy you will be notified via e-mail (if you have an account where we have your contact information) or another manner through the Services that we believe reasonably likely to reach you (which may include posting a new privacy policy on our Site – or a specific announcement on this page or on our blog).

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Site (or as otherwise indicated at the time of posting). In all cases, your continued use of our Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

# Contact Us

If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, please contact us at [email protected].

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