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Cobra App Privacy Policy

Last updated: September 2026

This policy explains how the Cobra mobile app handles information. It is separate from the cookie policy that governs this website.

Who this policy covers

This policy is provided by Waggoner Group, Inc. ("we"). Cobra is a private, internal application used by advisors and staff of Waggoner Financial, a Waggoner Group company, to manage referrals and prospective client relationships. It is not a consumer product. Access requires an account issued by the firm, and accounts are created and removed as part of employee onboarding and offboarding. There is no way to sign up for an account from within the app.

Information in the app

The app handles two distinct kinds of information.

Information about the person using the app

When an advisor signs in, we process their work email address and the account identifier we have assigned to them. We use this only to authenticate the session, to determine what the advisor is permitted to see and do, and to attribute records they create.

Information about prospective and existing clients

Advisors enter contact records into the app in the course of their work. These records may include a person's name, email address, phone number, who referred them, and notes on the status of the relationship.

Most records are typed in by the advisor. An advisor may also import one person at a time from their phone's contacts: choosing "Import from Contacts" opens the phone's own contact picker, and the app receives only the details of the single person the advisor selects, pre-filled into the form for them to review before saving. The app never browses, reads, or uploads the address book as a whole, and it does not read your location, photos, or any other information stored on the device.

How the information is used

Information in the app is used only to operate the app: to sign the advisor in, to display and organize their referral records, and to keep those records in sync with the firm's systems.

We do not use this information for advertising or marketing. We do not sell it. We do not share it with advertising networks or data brokers, and we do not use it to track individuals across other companies' apps or websites.

Where the information goes

Information entered in the app is stored on our systems.

Contact records created in the app are also written to Redtail, the customer relationship management system the firm uses, so that a referral entered on a phone appears alongside the rest of the firm's records. Redtail processes this information on our behalf.

Technical error reports and usage information are processed on our behalf by PostHog, as described below.

We may disclose information where we are required to do so by law, regulation, or valid legal process, or where necessary to meet our regulatory obligations as a financial services firm.

Error reporting and usage analytics

So that we can find and fix problems in the app, we use PostHog (opens in new tab) to record technical error reports and basic usage information. This covers crashes and unexpected errors, which screens were opened, and a small number of named actions such as adding a contact or creating a card. These records are associated with the advisor's account identifier so we can tell whether a problem affects one person or everyone.

This reporting is designed not to carry client information. The app does not record what is on screen, does not record taps, and reports screens by their general template rather than by the specific record being viewed. Information that looks like a name, email address, or phone number is removed from every report before it leaves the device.

The app contains no advertising software. This information is used only to operate and improve the app. It is not used for advertising, and it is not used to track anyone across other companies' apps or websites.

How the information is protected

Traffic between the app and our systems is encrypted in transit. Sign-in credentials are held in the device's system keychain rather than in ordinary app storage. Data cached on the device so the app can work quickly is cleared when the advisor signs out.

Access within the app is limited by role, so an advisor sees the records their position permits.

How long information is kept

Records created in the app are retained in the firm's systems for as long as necessary to operate the business and to satisfy the recordkeeping obligations that apply to us as a financial services firm.

Because accounts are issued and withdrawn by the firm, an individual advisor cannot delete their own account from within the app. When someone leaves the firm, their access is revoked centrally as part of offboarding.

Children

Cobra is a workplace tool for our advisors and staff. It is not directed at children and is not intended for anyone under 18.

Changes to this policy

If we change how the app handles information, we will update this page and revise the date above.

Questions?

If you believe your information appears in our records and you have a question or a request about it, please contact us. California residents can also use our Do Not Sell My Personal Information form.