Our Commitment to Your Privacy: Protecting clients’ privacy is of paramount importance to SkyOak Capital, Inc. (the “Firm” or “Advisor”). It is SkyOak’s policy that no private client financial information obtained by the Firm is sold or made available to third parties, except that:

Third parties may be used by the Firm to assist in the management or maintenance of client accounts (such as a custodian, broker or bank).
Client information may be released to client’s accountancy, legal and other third party representatives at client’s direction.
Client information may be released in accordance with applicable laws and regulations.

The Firm will not share nonpublic personal information about its clients with non-affiliated third parties without prior client consent, except for specific purposes described below. This notice explains the Firm’s collection, use, and safeguarding of client information.

How SkyOak Gathers Information: In connection with providing clients with investment management services, the Firm may obtain information about its clients from the following sources:

Client agreements and other information that clients provide to the Firm, whether in writing, in person, by telephone, electronically, or by any other means. This information may include a client’s name, address, phone number, email address, social security number, employment information, income, investment experience, and credit references;
Personal tax returns provided by the client;
Trusts, wills, and other estate planning documents provided by the client;
Transactions on a client’s behalf. This information may include the client’s account balances, positions, investment interests, and history;
Consumer reporting agencies. This information may include account information and credit history; and Public sources.

Sharing Information with Nonaffiliated Third Parties: Advisor only discloses non-public client information to nonaffiliated third parties when it is believed necessary for the Firm’s provision of services to you or as required or permitted by law, such as:

If you request or authorize the disclosure of the information;
To provide client account services or account maintenance;
To respond to a subpoena or court order, judicial process, law enforcement or regulatory authorities;
To perform services for the Firm or on its behalf to develop or maintain proprietary trading or other software
In connection with a proposed or actual sale, merger, or transfer of all or a portion of the Firm’s business or an operating unit;
To help prevent fraud;
With rating agencies, persons assessing compliance with industry standards, or to the attorneys, accountants and auditors of the Firm;
To comply with federal, state or local laws, rules and other applicable legal requirements; and
Pursuant to any other exceptions enumerated in the California Information Privacy Act.

SkyOak does not make any disclosure of client non-public personal information to other companies who may want to sell their products or services to you. For example, the Firm does not sell client lists and the Firm will not sell client names to catalog companies.

Opt-Out Provision: If at any time in the future, it is necessary to disclose any client personal information in a way that is inconsistent with this policy, SkyOak will give its clients advance notice of the proposed disclosure so that they will have the opportunity to opt-out of such disclosure. The Firm believes that sharing client private information under the circumstances noted above is either mandated by law or necessary for the Firm to conduct its business and to best service client accounts. Clients desiring to opt-out of the above disclosures should contact the Firm immediately to terminate its agreement with the client and arrange for the client to transfer the client’s account. If at any time in the future, it is necessary to disclose any of the Client’s personal information in a way that is inconsistent with this policy, SkyOak will give Clients advance notice of the proposed disclosure so that they will have the opportunity to opt-out of such disclosure.

Former Clients: This Privacy Policy continues to apply to all former clients. To Whom This Policy Applies: This Privacy Policy applies to individuals who obtain or have obtained services from SkyOak.

Our Security Practices and Information Accuracy: SkyOak takes steps to safeguard client information. Access to the personal and account information of clients is restricted to its employees and agents for business purposes only. The Firm maintains physical, electronic, and procedural safeguards to guard the Client’s personal information. Additionally, the Firm has internal controls to keep Client information as accurate and complete as possible. If you believe that any information about you, the Client is not accurate, please contact the Firm.

Other Information: SkyOak reserves the right to change this Statement of Privacy Policy. The examples contained within this Privacy Policy are illustrations and they are not intended to be exclusive. If you have any questions about this Privacy Policy, please contact Donald L. Watson, Chief Compliance Officer, or Jennifer Davis, President at 800-971-8070.

Opening Account Procedure: Opening an Account with to SkyOak Capital, Inc. through their custodian, Charles Schwab, as a Registered Investment Advisor requires the following:

Client completes Confidential Client Data Sheet;
Client reviews and signs one or more of the following: Investment Management and Service Agreement, Financial Planning Client Service Agreement, and/or Personal Wealth Manager-Family Office Service Agreement.
Clients complete an application to open an account with the custodian, Charles Schwab or Equity Institutional;
Client reviews SkyOak Capital’s ADV Part 2A and Part 2B
Client reviews Statement of Privacy Policy;
Client reviews Customer Information Sheet;
The client completes any additional forms to supplement the above documents if necessary to achieve the client’s investment goals and objectives
Investment Policy Statement, if applicable, will be reviewed and signed prior to investment strategy implantation.

Opening an account with to SkyOak Capital, Inc. through their broker-dealer, KW Securities, Corp. requires the following:

Client completes KW Securities, Corp. Account Information form;
Client completes KW Securities, Corp. Disclosure form;
Client completes Third-party Account Application Forms (i.e. Pershing, insurance company, mutual fund company, etc.);
Client reviews and/or completes any additional forms to supplement the above document if necessary to achieve clients investment goals and objectives;
Client reviews Customer Information Sheet;
Investment Policy Statement will be reviewed and signed prior to investment strategy implantation.

Business Continuity Plan: In the event an Investment Advisor Representative of to SkyOak Capital, Inc. is unable to supervise your account(s) or has left the company, unless otherwise prescribed by a separate Business Continuity Agreement made available to you, the supervision of your account(s) will be maintained with the same expertise and professionalism to which you have become accustomed. All investment decisions, proposals, and analyses will be supervised by the President, Chief Investment Officer, Chief Operating Officer, and Chief Compliance Officer working in cogence and in order of an authority. The client may at any time choose a specific Investment Advisor Representative to supervise their account(s).

Please see KW Securities, Corp. for their business continuity plan.