Privacy Policy

Overview

Open Invest Co. (“OpenInvest”, "we", or "us") are committed to protecting and respecting your privacy. This Privacy Policy sets out our policies and procedures for collecting, using and disclosing information provided to us by users of openinvest.co (“Open Invest” or the “Site(s)”), and on our broker partner sites. This Privacy Policy governs your use of our services and by using the Sites you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy. For purposes of compliance with the Gramm-Leach-Bliley Act (the “GLB Act”) and SEC Regulation S-P, this Privacy Policy shall serve as both your initial and annual “privacy notice” as defined under such regulations. If you have any questions or concerns regarding this statement, you should contact us at support@openinvest.co.

Changes to our Privacy Policy

This Privacy Policy may change from time to time. If we make a change to this Privacy Policy that we believe materially reduces your rights, we will provide you with prominent notice on Open Invest or send a notice to you by email. By continuing to use our services after those changes have become effective, you agree to be bound by the revised Privacy Policy.

Information Collected by Us

We collect user submitted account information such as name, email address, investment experience, and other financial information to identify you and send you notifications related to the use of the services offered by the Sites. We maintain information you submit in your profile on the Sites, and we also collect user submitted content about companies and investing and other information. We collect information from you when you send us feedback as well. Some information collected is not explicitly submitted by the user. Examples of such information include (but are not limited to): browser-type related information, IP address, requested URL, referring URL, and timestamp. See “Use of Cookies and IP Address” below. If you choose to use our paid service, we may also collect your brokerage account login credentials provided by you and information about your holdings in those accounts.

Additional Information Collected for Operations for the Paid Service

We may collect additional information from paid service members in order to rebalance user accounts in line with brokerage firm security requirements including:

We may collect other information from you during your use of the paid service. For example, if you sync your financial institution to the paid service, your financial institution may provide us with information about you and your account to facilitate our ability to provide our services to you and to reduce the amount of data you need to enter. The information we collect may include but is not limited to your name, age, salary, financial account information including financial institution, contributions, investment holdings and preferences, employment information, and contact information. We keep records of our advisory service, which may include but are not limited to records of the advice that we provide to you, your use of our services, and your communications to us about our services.

Blogs, Forums, and Wikis

If you use a blog, forum, wiki, or other publicly published content product on the Sites, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these forums.

How We Use Information

Information such as your full name and any personally identifiable information you have included in your profile may be shown to users, primarily in conjunction with any content you have contributed. We use information supplied to us to respond to your feedback or inquiries. In addition, part of the Open Invest service is a real time feed that displays user activity. For example, if you post an article, a streaming notice may be posted about that activity or the activity of other users. This is part of the Open Invest service and Open Invest users may not opt-out of this functionality. Your full name and email address may also be used when you send an email notification to another user on Open Invest. We may also use your email address to send you communications from us or messages that we send you on behalf of other users, but you may opt out of receiving emails by changing your email preferences in your profile settings. We never share your personally identifiable information with advertisers.

How We Use Information Collected Through the Paid Service

Your personal and investment information is maintained by OpenInvest to provide you with customized investment services and to fulfill our legal and regulatory requirements. By having more information about you, we are able to customize our services to your particular investment preferences. We may use your brokerage account information in order to rebalance your accounts and keep your accounts in line with the investment preferences that you specified when signing up for the paid service and selecting portfolio(s). Data that does not include personally identifiable information may be used for research purposes. For instance, we may compile data, excluding personally identifiable information, for purposes of demographic analysis and research.

We will send you service-related announcements on the rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

Browser-type related information, IP address, requested URL, referring URL, timestamp data, and other information help us diagnose problems with our servers, administer the Sites, and otherwise provide the highest possible level of service to you. In addition, we use this non- personally identifiable information to perform statistical analyses of user behavior and characteristics in order to measure interest in and use of the various areas of the site.

Updating/Accessing Personally Identifiable Information

If your personally identifiable information or your investment information changes, or if you no longer desire our service, you may correct, update, or delete/remove it by selecting Delete Account on your profile page or by emailing our Customer Support team at support@openinvest.co. We will respond to your request within 10 business days. Please note that even if we close your account, we may retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. Please also note that there might be latency in deleting information from our servers and backed-up versions might exist after deletion.

Use of Cookies and IP Addresses

Like most websites, the Sites require cookies to function properly. Cookies are small text files that reside on a user's computer and identify you as a unique user. We use cookies to refine our services and simplify the user experience. For example, the use of cookies allows registered users to enter our Sites without explicitly typing in their email address and password every time, and it allows us to personalize your experience on the Sites by, e.g., suggesting articles you may be interested in. For these reasons we tie personally identifiable information such as your email address to our cookies. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature; however, you should note that cookies might be necessary to provide you certain features (e.g., customized delivery of information) available on the Sites.

Advertising and Partner Sites

We use third-party advertising companies to serve ads when you visit the Sites. These advertising companies may use certain information (not including your name, address, email address, or telephone number) about your visits to the Sites, partner sites and other websites in order to provide advertisements about goods and services of interest to you. Unless we have your express permission, we will not share any personally identifiable information about you with any advertising companies or with the providers of the advertised goods and services, and these companies will not collect such information on our behalf. If you choose to use these separate goods and services, disclose information to the providers, or grant them permission to collection information about you, then their use of your information is governed by their privacy policies.

Recommendations of Certain Third Parties

We may from time to time recommend third-party broker-dealers and/or investment advisors to you. If you indicate your interest in learning more about a recommended broker-dealer or investment advisor, we will request your consent to collect information from you, including personally identifiable information, for communication to them. The communication of such information to the third- party broker-dealer or investment advisor will be subject to their privacy policy.

Transfer/Disclosure of Information

Some of the information you provide on our Sites is publicly exposed in an aggregated and/or anonymized manner unless otherwise noted. However, except as set forth in this Privacy Policy, we do not sell, rent, share, trade or give away any of your personal information. We do not share your personal information for a third parties' promotional use. We will disclose information about individual users to governmental or judicial authorities or law enforcement agencies, or to other individuals or entities, in response to subpoenas, court orders, or other legal processes. Further, we may share information in order to investigate, prevent, or take action regarding illegal activities or suspected fraud, or to enforce or apply the terms and conditions of this Privacy Policy.

We reserve the right to transfer your personal information in the event of a transfer of ownership of OpenInvest, such as an acquisition by or merger with another company. In such an event, we will notify you before information about you is transferred and becomes subject to a different privacy policy. We will notify you when information about you may be provided to third parties in ways other than explained above, and you will have the option to prevent such information sharing.

Security

OpenInvest accounts are password-protected. We use our reasonable best efforts to protect our users' information. If you have any questions about the security on our Sites, then please contact us. We follow generally accepted industry standards to protect the personally identifiable information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet or method of electronic storage is 100% secure.

Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot assure you that personally identifiable information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy. For more information about our security protocols, please review the FAQ section.

You hereby acknowledge that we are not responsible for any intercepted information sent via the Internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner.

Email/Direct Mail and Opt-out

Registered members of the Sites can opt-out of receiving personal messages from users or notifications from us by going to the preferences section of the profile area of the relevant Site(s). Users that do not wish to receive emails may opt-out of receiving any communications by following the instructions contained in all emails from us.

Controlling Your Personal Information

You should be aware that when you voluntarily disclose personally identifiable information (e.g., user name, e-mail address) via reviews, messages, forums, and/or postings on openinvest.co, that information, along with any substantive information disclosed in your communication, can be collected and correlated and used by third parties and may result in unsolicited messages from other posters or third parties. Such activities are beyond our control. Please do not post any personal information on openinvest.co that you expect to keep private. As a registered user of the Sites, you can modify your personal information at any time by accessing the user settings area of openinvest.co, as applicable.

Respecting Children's Privacy

This website is not directed to children, and we do not knowingly solicit information from any child under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without his or her consent, he or she should contact us. Should a child whom we know to be under 13 send personal information to us, we will delete it as soon as possible.

Our Sites may contain links to third party websites to which we have no affiliation. Unless you expressly authorize us to do so, we will not share your personal information with such third party websites. We are not responsible for the privacy practices of third party websites and suggest you read any such policies that may apply to you.

Frames and Partner Sites

Our Sites utilizes framing techniques to make it appear that the user is still on one of our Sites when the user is actually on a third party website. We do this so that you will have a more seamless experience on the Sites. The privacy policy of the site that governs any collection of data will appear on those pages.

Modifications to the Privacy Policy

By using the Sites, you signify your agreement to the terms of our Privacy Policy. If you do not agree with these terms, you should not use the Sites. We may modify this Privacy Policy at any time. If a material change is made to this Privacy Policy and/or the way we use our users' personally identifiable information, then we will post a prominent notice of the nature of such change on the first page of this Privacy Policy. You are responsible for reviewing this Privacy Policy periodically to ensure that you are aware of any changes to it. Your continued use of the Sites indicates your assent to any changes to this Privacy Policy.

Contact

If you have questions, comments, concerns or feedback regarding this Privacy Policy or any other privacy or security concern, please send an e-mail to support@openinvest.co.