Privacy Policy by OpenTrade

Privacy Policy

Last Updated: February 12, 2021

OpenTrade, Inc, a Washington corporation ("we", "us" or the "Company"), respect your privacy and are committed to protecting it through compliance with this Privacy Policy.

This Privacy Policy describes and governs the manner in which we collect, use, maintain and disclose information about you when you use our website, mobile applications and other online services, including our user editing permissions and services and catalog management system (collectively, the "Services") and/or any website, mobile applications, online portal or other online services developed by us for any of our clients ("Client Services"). Please read this Privacy Policy carefully before you start to use the Services or Client Services, as applicable. By accessing and/or using the Services or Client Services, you accept and agree to be bound and abide by this Privacy Policy and our Terms of Use available at www.opentradeinc.com/tou (the "Terms of Use"),
incorporated herein by reference, and to comply with all applicable laws, rules and regulations (collectively, "Applicable Law"). If you do not want to agree to this Privacy Policy and the Terms of Use, you must not access or use the Services or Client Services.

If you are a client of the Company for which we have developed a website, mobile application, online portal or other online services, this Privacy Policy and the Terms of Use shall, to the extent applicable, govern your use of such Client Services (and the use of customers, distributors, suppliers or any other third party you authorize to access such Client Services). However, we encourage you to implement your own privacy policy, terms of use and any other applicable policies or agreements to govern the relationship between you and each such customer, distributor, supplier or other third party you authorize to use such Client Services. Should any conflict arise between any such privacy policy, terms of use or other applicable policy or agreement, this Privacy Policy and the Terms of Use shall govern with respect to any Services and/or Client Services accessed, edited or otherwise used through our Services.

In accessing any Client Services, you may be subject to, and may be required to agree to be bound by, privacy policies, terms of use and any other policies and agreements that may be applicable to such Client Services or otherwise required by the applicable Company client.

 

Personal Information

We may collect personal information from you in a variety of ways, including the following key categories and types of personal information:

  • Contact information: Name, username, address, email address and phone number, name and email address of spouse, if applicable, and name, jurisdiction of incorporation or formation, address and phone number of company or business entity.
  • Financial information: Credit card and bank and automated clearing house (ACH) information, including account number and routing number and bank name, address and payment reference.
  • Personal information: We will collect your social security number and the tax ID of your company or business entity.
  • Information about your transaction: We will collect information about any transaction for which you use the Services or Client Services, including information about the counterparty, transaction details and timing, and identity and location of the subject securities, assets or property. We also collect information relating to your purchase orders, invoices and other economic activities you conduct on our Services or any Client Services.
  • Professional or employment-related information: Professional and employment information shared by you, including your position and employer.
  • Geolocation data: The general region or area from which you access our Services.
  • Internet or other online activity: Referral channels that led you to our Services, or to any Client Services, browsing and click history and information about how you navigate our Services or any Client Services.
  • Information from public sources: We may obtain information about you and (if applicable) your employer on the internet or through offline sources and other public or commercial sources.

 

How We Use Collected Information

We may collect and use your personal information for the following purposes:

  • To provide and improve customer service: We use your contact information to answer your questions and respond to your requests and enquiries, notify you of changes to the Services, provide you the Services and improve and maintain functionality of our Services.
  • For analytical purposes: We use your internet activity, browsing history and geolocation data to analyze preferences, trends and statistics. We may also use your activity on our Services in an anonymized and aggregate way in order to improve our Services. We may also use your information to protect the Company, our Services and our website, and to prevent fraud, theft and misconduct.
  • For relevant updates, marketing and promotional purposes: We use your contact information, employment-related information and various inferences described above to send you relevant, articles, blog posts, newsletters, podcasts and other information we think may be relevant to you. We may also use information about your use of our Services in an anonymized and aggregate way to analyze trends and statistics and to promote and market our Services.

 

How We Collect Your Personal Information

We collect personal information from the following sources:

  • Directly: We collect personal information directly from you. When you register for the Services or any Client Services, submit information in an online form, request information from us, or otherwise communicate with us or our support personnel, you may provide us with information, for example, your name, email address, phone number and physical address. By providing us with this information, you consent to your information being collected, used, disclosed, processed and stored by us in accordance with this Privacy Policy.
  • Passively: We and our service providers collect personal information from you passively from the internet and other automatic data collection tools, such as cookies and web beacons, which are summarized below:
    • Cookies (or browser cookies): A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.
    • Web Beacons: Pages of our website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
    • Tracking Tools: We use the following tracking tools:
      • Google Analytics and Adwords: We use Google tools such as Google Analytics and Google Adwords to understand how users use our website. This includes looking at where a visitor comes from and where they go when they leave our site. Google Analytics provides an opt-out for its tool here.
      • Other tracking tools: We may deploy other automatic tracking tools in the future. Similar to the tools we currently use, such future tracking tools will track data about our visitors only in the aggregate and on an anonymized basis and will not reveal personal information about you.

 

When We Share Your Personal Information with Third Parties

  • With service providers who do things on our behalf: For example, we will share information with vendors and contractors who conduct email marketing for us or who assist us with developing and providing the Services and any Client Services, and customer support. Such service providers may reside outside the United States and in countries that may not provide the same level of protections as the laws of the United States.
  • With third parties as directed by you or to support transactions you engage in via the Services or Client Services: We may share your information with third parties with your consent or as requested by you, or in connection with a transaction you engage in through the Services.
  • In accordance with applicable law: We may share your information with third parties with your consent or as requested by you, or in connection with a transaction you engage in through the Services.
  • In connection with sale of the Company: In the event of a reorganization, merger, or sale we may transfer your personal information we collect to the relevant third party.

 

We Do Not Sell Your Personal Information

We do not sell, trade, or rent your personal information to others.

 

Third-Party Links and Websites

Our Services and Client Services may contain advertising, links or other content from the websites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties (collectively, the "Third-Party Services"). We do not control the content or links that appear on these Third-Party Services and are not responsible for the practices employed by such Third-Party Services. In addition, these Third-Party Services may have their own privacy policies and customer service policies. Browsing and interacting on any of these Third-Party Services are subject to such Third-Party Services' own terms and policies.

 

Our Content on Third-Party Services

Our Services and Client Services may be provided on or hosted on a third-party platform or otherwise make use of Third-Party Services. We do not control the content or links that appear on these Third-Party Services and are not responsible for the practices employed by such Third-Party Services. Your browsing and interacting on any of these Third-Party Services are subject to such Third-Party Services' own terms and policies. Any visit you make to those other services is at your own risk. Such third parties' use of any information you share is governed by the third party's privacy policy. The Services and Client Services may also use third-party service remarketing services to advertise to previous visitors to the Services or Client Services, as applicable, on such Third-Party Services. Such third parties may use tracking technology (e.g., cookies) to serve ads to you based on your past activity on our Services or Client Services and other websites and applications, subject to their own privacy policies.

 

Your Choices

You have certain choices on how we treat your personal information, described below:

  • Modifications to Personal Information: You may review and request modifications to your personal information by editing your profile directly on our website or by contacting us at info@opentradeinc.com. Please note that we will retain data for as long as it is reasonably necessary to fulfill the purpose for which it has been collected or as required or permitted by applicable law. If you provide us with updated information, we will do our best to keep your information accurate and up-to-date. We will make good-faith efforts to make requested changes in any active database as soon as practicable.
  • Marketing Communications: You can opt out of promotional marketing communications by contacting us at info@opentradeinc.com. We may give choices about other emails and communications you receive from us. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business.
  • Ad Choices: Some advertisements and other content may be delivered by third-party advertising networks and advertisers that may use cookies and similar and/or your advertiser ID for mobile devices to collect and track information such as demographic information, inferred interests, aggregated information, and activity to assist them in delivering advertising that is more relevant to your interests. To find out more about third-party advertising networks and similar entities that use these technologies, see www.aboutads.info. If you would like to opt-out of such ad networks' and services' advertising practices, go to www.aboutads.info/choices to opt out in desktop and mobile web browsers. You may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile applications.
  • Tracking Technology: You may turn off part or all of our tracking software that has been placed on your computer by following the instructions on your browser. On a mobile device, you may turn off part or all of mobile tracking through your mobile device settings. However, if you prevent the use of tracking software or tracking through your mobile device, it will be more difficult, and may be impossible, for you to use the Services or Client Services, or portions of the Services or Client Services.
  • Location and Analytics: If we use Third-Party Services to automatically collect your personal information, such Third-Party Services may offer you a choice to stop the automatic collection of your information. Please see our "How we collect your personal information" above with respect to our tracking tools.
  • Cookies: Most web browsers are set by default to accept cookies. You can usually set your browser to remove or reject cookies. Please note if you choose to reject, this could affect the availability and functionality of our Services and Client Services.
  • Not Providing Personal Information: You may choose not to provide personal information to us. However, if you do not provide personal information, we may not be able to offer you all or part of our Services or Client Services.

 

Telemarketing

Without limiting the foregoing, by providing your personal information to us via the Services or Client Services, you acknowledge and agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the "Rule") and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission's Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing, including by means of a pre-recorded message and automated voice dialing, in accordance with the Rule and the applicable state do-not-call regulations. Your acceptance of this Privacy Policy constitutes your express written consent to receive telemarketing calls from third-party marketers, including by means of a pre-recorded message and automated voice dialing. Your consent will be effective regardless of whether the number you have provided: (a) is a home, business, or cell phone line; or (b) is or will be registered on any state or federal do-not-call list.

 

Where Your Information Is Stored

We store your information in the United States. However we may transfer your information to our service providers who may reside in other countries.

By using the Services or Client Services, or otherwise providing information to us, you understand and consent to having any personal information transferred to and processed in the United States. If you reside in the European Union (the "EU"), we will transfer your personal information pursuant to EU data protection laws. You understand that the United States may not provide the same level of protections as the laws in your country. United States data protection and other relevant laws may not be the same as those in your jurisdiction. In certain circumstances law enforcement or regulatory agencies, courts or security authorities in the United States may be entitled to access your personal information.

 

Information Security

We use commercially reasonable security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure. However, we cannot guarantee the complete safety of your information. It is your responsibility to keep your information confidential.

 

How Long We Keep Your Information

We retain, store and use your information for least amount of time necessary for our relationship with you and to provide you access to our Services and Client Services, and in accordance with data retention policies and applicable law.

 

Our Services and Client Services Are Not Intended For Children

Our Services and Client Services are not directed to children under the age of 18. We do not knowingly collect information, including personal information, from children. If we obtain actual knowledge that we have collected such information from children, then we will promptly delete it. If you believe we have mistakenly collected information from children listed above, please contact us at Our Services and Client Services are not directed to children under the age of 18. We do not knowingly collect information, including personal information, from children. If we obtain actual knowledge that we have collected such information from children, then we will promptly delete it. If you believe we have mistakenly collected information from children listed above, please contact us atinfo@opentradeinc.com.

 

Information for European Economic Area Residents

If you are a resident of the European Economic Area ("EEA"), you have certain rights and protections under applicable law regarding the processing of your personal information. The term "personal information" has the meaning given to it by the European General Data Protection Regulation ("GDPR"). When we process your personal information as described in this Privacy Policy, we will only do so when we have a legitimate interest in processing your personal information (for example, our legitimate interest in providing the Services and Client Services, responding to your inquiries, or sending you marketing communications), when the processing is necessary for the performance of a contract between you and us, when the processing is necessary for us to comply with the law, or when you give us consent to process your personal information. You have the right to revoke your consent at any time. You also have the right to access personal information we hold about you and to ask that your personal information be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may contact us as indicated below. If you have a concern about our processing of personal information that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside.

For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

 

"Do Not Track" Policy as Required by California Online Privacy Protection Act ("CalOPPA")

Our Service does not respond to Do Not Track ("DNT") signals. However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

 

Your California Privacy Rights

If you are a California resident, California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Services or Client Services to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes and to opt out of sharing your personal information with such third parties. To make such a request, please send an email to info@opentradeinc.com.

 

Usage and Deletion of Personal Information

You may request what personal information we have collected, used and disclosed about you as well as the identity of the third parties to which we have disclosed your personal information. You may also request deletion of your personal information. Please note that we may not delete all of your information if: (1) we need it to complete a service as requested by you or perform under a contract we have with you; (2) we need such information to repair any errors to our Services or Client Services, or to detect data security violations; (3) we have the right to hold such personal information pursuant to the Terms of Use or any other agreement we have with you; or (4) we need such information to protect against fraud or illegal activity or to comply with applicable law. Please note that if we delete your personal information, we may not be able to provide you the Services or Client Services with the same functionality.

To make any request for personal information or deletion, please send an email to info@opentradeinc.com.

 

Changes to this Privacy Policy

We have the discretion to update this Privacy Policy at any time. We encourage you to frequently check this page for any changes. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications. Your continued use of our Services or Client Services shall be deemed an acceptance of our revised policy.

 

You Can Contact Us

If you have any questions about this Privacy Policy, you can email us at info@opentradeinc.com.