This Privacy Policy describes how Open Advisor collects, uses, discloses, transfers, stores, retains or otherwise processes your information when the Company or individual (the “Company” or “Open Advisor”) uses Open Advisor services and other products provided by Open Advisor (collectively, the “Services”).

This Privacy Policy applies to information collected in connection with the Services that we provide to your Company. Please read this Privacy Policy carefully. By continuing to interact with our Services, you are consenting to the practices in this Privacy Policy.

Our Privacy Policy explains:

INFORMATION WE COLLECT ABOUT YOUR COMPANY

We use data your Company puts into our systems when your Company uses our Services for any other matter in relation with the Services. Whenever a User browses, interacts or creates an account on the Websites Open Advisor, Open Advisor collects different kind of data to be able to provide the Services thereon available. Such information can be as follows:

HOW WE USE YOUR INFORMATION

We may collect, use and share information about your Company for the following reasons:

• Performing, Improving, and Developing our Services

  Delivering the information and support you request, including technical notices, security alerts, and support and administrative messages such as to resolve disputes, collect fees, and provide assistance for problems with our Services.

  Determining whether the Services are available in your country or location.

  Developing new products and services.

  Displaying your historical transaction or appointment information.

  Improving, personalizing, and facilitating your use of our Services;

  Processing or recording payment transactions.

  Providing, maintaining, and improving our Services, which could include analytics information.

  Doing internal research, measuring, tracking, and analyzing trends and usage.

  Otherwise providing you with Open Advisor products and features you choose to use.

• Communicating with You About our Services

  Sending you surveys and getting your feedback about our Services.

  Providing information about and promoting our Open Advisor services to you.

  Sending you information we think you may find useful or which you have requested from us about our products and services.

• Protecting our Services and Maintaining a Trusted Environment

  Conducting investigations, complying with and enforcing applicable laws, regulations, legal requirements, and industry standards, and responding to lawful requests for information from the government or to a valid legal process.

  Contacting you to resolve disputes, collect fees, and help you with our Services.

  Debugging to identify and fix errors that impair how our Services function.

  Making sure you follow our terms of use or other applicable agreements or policies.

  Investigating, detecting, preventing, recovering from or reporting fraud, misrepresentations, security breaches or incidents, other potentially prohibited, malicious, or illegal activities, or to otherwise help protect your account, including to dispute chargebacks on your behalf.

  Verifying or maintaining the quality and safety of our Services.

  Verifying your identity (e.g., through government-issued identification numbers).

• Advertising and Marketing

  Marketing our Services to you; and Communicating with you about opportunities, products, services, contests, promotions, discounts, incentives, surveys, and rewards offered by us and select partners.

  If we send you marketing emails, each email will have instructions on how you can “opt out” of getting future marketing from us.

• Other Uses

  For any other reason, we may tell you about it from time to time.

WHEN AND WITH WHOM WE SHARE YOUR COMPANY INFORMATION

We may share the personal information described in the “Information We Collect About Your Company” section with the following categories of service providers and third parties:

• With our Affiliates and Group Companies

  With our group companies and corporate affiliates, for the reasons outlined above. For example, we may share your information internally to understand how you engage with Open Advisor products to help make our Services better for you and for everyone and to help us build Services tailored to your preferences.

• With our Service Providers

  With service providers who help us provide, maintain, and improve our Services, partners, and other entities that help us provide the Services.

• Business Transfers and Corporate Changes

  To a subsequent owner, co-owner, or operator of one or more of the Services; or If we do or try to do a corporate merger, consolidation, or restructuring (including during due diligence and negotiation of these); the sale of substantially all of our stock and/or assets; the financing, acquisition, divestiture, or dissolution of all or a portion of our business; or other corporate change.

• Safety and Compliance with Law

  If we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or governmental request (e.g., from creditors, tax authorities, law enforcement agencies, in response to a garnishment, levy, or lien notice, etc.); (ii) to establish, exercise or defend our legal rights; (iii) to enforce or comply with our general terms or other applicable agreements or policies; (iv) to protect our or our customers’ rights or property, or the security or integrity of our Services; (v) for an investigation of suspected or actual illegal activity; or (vi) to protect us, users of our Services or the public from harm, fraud, or potentially prohibited or illegal activities.

• With Your Consent

  With your consent. For example: At your direction or as described at the time you agree to share; or When you authorize a third party application or website to access your information.

• With Others

  With other companies who deliver services on our behalf.

• Aggregated and Anonymized Information

  Open Advisor may share (within our group of companies or affiliates, or with service providers or other third parties) aggregated and anonymized information that does not specifically identify you or any individual user of our Services.

HOW LONG WE KEEP YOUR COMPANY INFORMATION

We generally keep your Company information as long as reasonably necessary to provide you the Services or to comply with applicable law. However, even after you deactivate your Services, we can retain copies of information about you and any transactions or Services in which you may have participated for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our general terms or other applicable agreements or policies, or to take any other actions consistent with applicable law.

YOUR COMPANY DATA CHOICES

• Company Information

  You may access, change, or correct information that you have provided to Open Advisor at any time or by making a request to us. We will need to verify your identity before granting access or otherwise changing or correcting your information.

• Location Information

  In order to provide certain Services, we may request access to location information, including precise geolocation information collected from your device. If you do not consent to the collection of this information, certain Services will not function properly and you will not be able to use those Services. You can stop our collection of location information at any time by changing the preferences on your mobile device. If you do so, some of our mobile applications will no longer function. You also may stop our collection of location information via mobile application by following the standard uninstall process to remove all Open Advisor mobile applications from your device.

• Promotional Communications

  You can opt out of receiving promotional messages from Open Advisor by following the instructions in those messages, by informing the caller that you would not like to receive future promotional calls, or by sending us an e-mail at [XX]. Opting out of receiving communications may impact your use of the Services. If you decide to opt out, we may still send you non-promotional communications, such as digital receipts and messages about your account or our ongoing business relations.

• Rights of California Residents

  Open Advisor, to the extent required by any applicable law, disclose, delete or take any other action with respect to any of personal data that is collected by us from residents of California. Residents of California may make a request pursuant to the California Consumer Privacy Protection Act (the “California Act”) to have us, among other things:

  Disclose to you:

  The categories of your personal data that is collected by us.

  The categories of sources from whom or which such personal data is collected by us.

  The purposes for our collecting such personal data.

  The categories of third parties to whom or which we transfer such personal data.

  The specific pieces of such personal data collected by us.

  If such personal data is sold or disclosed for a business purpose to a third party, the categories of such personal data that are sold or disclosed for a business purpose, and the categories of third parties to which or whom such personal data are sold or disclosed for a business purpose.

  Except in certain circumstances, delete your personal data that is collected by us.

  Any such request by an individual under the California Act (1) can only be made twice in a 12-month period, (2) will require the collection of certain information by us to verify the identity of such individual, and (3) can be submitted to us at [XXX]. We will respond to any such request within 45 days after receiving it.

  We will not discriminate against any individual for exercising any right made available to such individual under the California Act.

European Privacy Rights

Subject to certain limitations and exceptions, if you are in the European Economic Area (EEA), you have the following rights under the General Data Protection Regulation (GDPR):

• Access to personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Correction of personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of personal data. This enables you to ask us to delete personal data when there is no good reason for us to continue to process it. You also have the right to ask us to delete your personal data when you have successfully exercised your right to object to processing, when we may have processed your information unlawfully or when we are required to erase your personal data to comply with applicable law.

• Restriction of processing personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) when our use of personal data is unlawful, but you do not want us to erase it; (c) when you want us to hold personal data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of personal data, subject to our verifying whether we have an overriding legitimate interest to continue using it.

• Request transfer of personal data. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.

• Right to withdraw consent. You can withdraw your consent at any time when we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

CHILDRENʼS PERSONAL INFORMATION

Our Services are general audience services not directed at children under the age of 18. If we learn that any information we collect has been provided by a child under the age of 18, we will promptly delete that information.

HOW WE SECURE INFORMATION

We take reasonable measures, including administrative, technical, and physical safeguards, to protect your Company information from loss, theft, and misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, the internet is not a 100% secure environment, and we cannot guarantee absolute security of the transmission or storage of your information. We hold information about your Company both at our own premises and with the assistance of third-party service providers.

STORAGE AND PROCESSING

We may, and we may use third-party service providers to, process and store your information in the United States, Canada, the European Union, the United Arab Emirates and other countries.

We may link to other sites or have third party sites we don’t control

We may link to third-party sites. Our sites may also include third party content that collects information. We do not control these third parties. This Policy does not apply to the privacy practices of that website. Please read the privacy policy of other websites carefully. We are not responsible for the practices of these third-party sites.

CHANGES TO THIS PRIVACY POLICY

Open Advisor reserves the right to, and may from time to time, make changes to this privacy policy. If this policy changes, the revised policy will be posted on the Open Advisor home page. Please check this policy on the site frequently. Your continued use of Open Advisor constitutes acceptance of such changes in this policy, except where further steps are required by applicable law. It is your responsibility to review the Privacy Policy periodically. This policy was last updated on the date set out at the end of the policy.

CONTACT US

You can contact our privacy team with any questions or concerns at the address below.

Please contact our privacy team with any questions or concerns regarding this Privacy Policy to info@openadvisor.app