Openfolio Privacy Policyy

Last Updated: May 12, 2017

Welcome to Openfolio. This Privacy Policy applies to your access and use of the Openfolio online services, including our website (www.openfolio.com), online and mobile applications and any other sites or services that link to this Privacy Policy (the “Services”). By downloading, accessing or using any of the Services, you are agreeing that you have read and agree to be bound by this Privacy Policy. If you disagree with any part of this Privacy Policy, please do not use the Services. If you have questions about this Privacy Policy or the Services, you may always contact us at support@openfolio.com (“Openfolio Support”).

Openfolio (“we” or “us”) wants you to get the most out of your use of the Services. This Privacy Policy describes the types of personal information we may collect from you when you visit and use the Services, and how we may use, share and protect that information. Please note, this Privacy Policy applies only to information collected through your use of the Services, and does not apply to information collected through or by third-party software you may download through the Services, third-party websites to which the Services link or third-party service providers who provide services to us and you in connection with the Services. Please consult the privacy policies of those third parties for more information. Please read on for more details about our Privacy Policy.

You can jump to specific areas of our Privacy Policy by clicking on the links below, or you can read on for the full Privacy Policy: 

What Kind of Information We Collect
How We Use the Information We Collect
How We May Share the Personal Information We Collect
How We May Share the Usage Information We Collect
How We Protect Your Personal Information
Management of Your Information
Cookies, Tracking Tools, and Internet-Based Advertising
Children’s Online Privacy
International
California Residents
Updates to this Policy
Contact Us

What Kind Of Information We Collect

Information You Provide to Us

When you visit, access, download or use any of the Services, you may choose to provide us with information that identifies you or relates to you as an individual (“Personal Information”). Personal Information may include your name, mailing address, telephone number, email address, date of birth, username and password, security questions and answers, and other personal information you choose to provide through your use of the Services.

We collect information from you when you create an account, sign in, contact us, or give us feedback. We also collect any other information that you submit through the Services, such as information you share with other Openfolio users through our forums or messaging or chat functions.

When you set up your user profile on Openfolio or otherwise use the Services, you may choose to link the Services with information from your other financial accounts, such as brokerage accounts. In order to link to these accounts, you will be asked to provide login information for these accounts (“Broker Login Information”). However, as opposed to the Personal Information and Usage Information (as defined below) that we collect and store on our systems, we do not store Broker Login Information on our systems. When you enter the Broker Login Information for your financial accounts, that information passes directly from you to our third-party service providers, who use the Broker Login Information to establish connections between your financial accounts and the Services. Through these connections, we receive and collect information about the performance of your brokerage accounts and use it to generate your Openfolio user profile, provide historical data regarding your performance history, create community-sourced benchmarks (such as the Openfolio Investor Average), compare your portfolio performance against those benchmarks and otherwise use it to provide the Services and enhance your Openfolio experience. We do not otherwise have access to your Broker Login Information.

Information We Collect Through Your Use of the Online Services

In addition, we automatically collect information when you use the Services (“Usage Information”), such as the pages, functions and other content you viewed or used, websites you visited before and after you use the Services, date/time stamp, IP address, Internet Service Provider, operating system, browser and device information, geolocation information, clickstream data and other information collected through cookies and other tracking tools (please see the section titled “Cookies, Tracking Tools and Interest-Based Advertising”).

Please remember that when you link to the Services through any third-party site, application or service, you are bound by the privacy policy of the third-party site, application or service, and we do not control and are not responsible for the privacy practices of such sites. You should consult the privacy policy of such sites to determine the information practices of those sites.

Information We Collect Through Third Parties

We may also collect information about you from third parties. For example, when you link your financial accounts to the Services, we receive information about those accounts, including the performance of those accounts, from the third-party financial institutions with which you have those accounts. If you use Facebook or other services to access, link to or use ours Services, we receive demographic and other Personal Information through those services. We may also receive information from third parties and use it to supplement the Personal Information that you have provided to us. Last, we sometimes collect Personal Information from other users of the Services, such as when they refer-a-friend to us and provide us with your email address or other Personal Information.

Of course, our Services may change over time as we strive to enhance your experience, and we may introduce features that collect new and different types of information.

How We Use The Information We Collect

We may use the information we collect, including Personal Information, for the purposes described in this Privacy Policy or as otherwise disclosed to you through the Services.  First and foremost, we use the information we collect to create, maintain and improve our Services. For example, we use the information we collect to:

  • Create, offer and improve the Services;
  • Register an account for you;
  • Process and manage your use of the Services;
  • Track your use of the Services to customize your experience;
  • Respond to your inquiries or requests;
  • Communicate with you through various means regarding your use of the Services;
  • Offer you additional products or services that may be of interest to you;
  • Enhance the security of our Services;
  • Enforce our Terms of Use and other policies; and
  • Otherwise further our business purposes, including performing data analysis, audits, fraud monitoring and prevention, identify usage trends, determine the effectiveness of our promotional campaigns and operate, improve and expand our business activities.

How We May Share the Personal Information We Collect

We generally won’t disclose your Personal Information to anyone outside of Openfolio or our affiliates, except in the following circumstances.

Service Providers

We may disclose your Personal Information and Usage Information to third-party service providers (“Providers”) which we engage to provide us and you with various services. Examples of Providers include services, like Facebook, through which you access our Services, data analysis firms, credit card processing companies, website hosting providers, fraud detection and identity verification services, customer service, e-mail and SMS vendors, auditing firms and other providers. Providers also include any co-promotion partners with which we jointly develop or market products or services. Some Providers may collect information on our behalf or through the Services. These third parties may be provided with access to Personal Information needed to perform their functions, but they may not use such information other than on our behalf and subject to contracts that protect the confidentiality of the information.

Affiliates

We may disclose Personal Information to our affiliates for the purposes described in this Privacy Policy, including for marketing purposes, and to be consistent with our goal of providing you with excellent products and services.

Sharing at Your Request

We may disclose your Personal Information to third parties in order to perform services you request or functions you initiate, such as when you post information and materials on message boards and forums, including on our Facebook or Twitter page or any of our other online properties.   Please note that when you post information in a public forum, it becomes public information.  In addition, we may disclose your Personal Information in order to identify you to anyone to whom you send communications through the Services. In addition, any information you choose to include on your Openfolio user profile will be visible to those Openfolio users whom you allow to view your profile.

Corporate Transactions

We may disclose your Personal Information to a third party in connection with a corporate reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock, including in connection with any bankruptcy or similar proceedings.

In Compliance with Law

In addition, we may use or disclose your Personal Information as we deem necessary or appropriate: (1) under applicable law; (2) to respond to requests from governmental authorities including those outside your country of residence; (3) to comply with subpoenas and other legal processes; (4) to pursue available remedies or limit damages we may sustain; (5) to protect our operations, rights or properties and those of our affiliates; and (6) to enforce our Terms of Use and other applicable policies.

Aggregate or De-Identified

We may aggregate your Personal Information and Usage Information with that of other users of the Services and share that aggregated data with third parties, but only in a de-identified form. We use aggregated data to create many of the community-sourced benchmarks that we feature within the Services, including the Openfolio Investor Average. We also may provide the aggregated and de-identified data to third parties in exchange for access to the products or services that they provide, to promote our Services, or to generate other revenue.

How We May Share the Usage Information We Collect

Similarly, we may share Usage Information for any purpose not prohibited by law.  In particular, we may collect, compile, store, publish, promote, report, sell, or otherwise disclose or use any and all Usage Information, provided that such information does not personally identify you.

 

How We Protect Your Personal Information

We employ technical, administrative and procedural tools in an attempt to safeguard your Personal Information and other information from unauthorized access or use. No such measure is ever 100% effective, so we do not guarantee that your Personal Information and other information will be completely secure from theft, loss, or unauthorized access or use, and we make no representation as to the reasonableness or efficacy of the measures we use to safeguard such information. Users are responsible for maintaining the secrecy of their own passwords. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us by contacting Openfolio Support. If you believe any of your broker accounts or associated log-in information have been compromised, notify your brokers immediately.

Management of Your Information

You may always manage, update and correct the Personal Information we have on file about you by logging into your user account. Alternatively, you may contact us to request that it be updated by contacting Openfolio Support.

Cookies, Tracking Tools and Interest-Based Advertising

 

Cookies

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on the Services. This Privacy Policy covers the use of cookies on the Services only and does not cover the use of cookies by any advertisers. We use both session ID and persistent cookies. A session ID cookie expires when you close your browser. We use session cookies to make it easier for you to navigate the Services. We use cookies for managing your browser and mobile sessions for your convenience. A persistent cookie remains on your hard drive for an extended period of time. You can often remove persistent cookies by following directions provided in your Internet browser’s “help” file. We set a persistent cookie to store your password, so you do not have to enter it more than once. Persistent cookies also enable us to track and target the interests of our users to enhance the experience of the Services.

Some of our Providers (e.g., advertisers) may use cookies within our Services. We have no access to or control over these cookies or those used on third-party websites.

The acceptance and storage of cookies can be managed through your browser’s security settings. If you reject cookies, you may still use the Services, but your ability to use some features of the Services may be limited.

To find out more about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit  https://allaboutdnt.com/.

  

Tracking Tools

In addition to cookies, we use other tracking technologies to collect Usage Information about your use of the Services, including tracking pixels, web beacons, log files, and others (together with cookies, the “Tools”). 

We use Tools to better understand, customize and improve user experience with the Services and manage our online advertising program. For example, we use Tools to help us understand how users engage with and navigate our Services, e.g., how and when pages in the Services are visited and by how many visitors. We are also able to offer our users a more customized, relevant experience on the Services using these Tools by delivering content and functionality based on your preferences and interests. If you have provided us with Personal Information, e.g., through a registration or a request for certain materials, we may associate this Personal Information with Usage Information gathered through the Tools. This allows us to offer increased personalization and functionality.

 

Do Not Track

We are monitoring the development of do not track functionality (“DNT”). At this time, we do not change our practices in response to DNT browser settings. For information about DNT, please visit https://allaboutdnt.com/.

Children’s Online Privacy

Openfolio recognizes the importance of protecting the privacy of children online. The Services are intended for general audiences and are not directed to children under 13. We do not knowingly collect data from or maintain data about users who are under the age of 13.

International

Any information you provide to us, including Personal Information, may be transferred to other countries, as permitted by applicable law. Other countries may not offer the same level of legal protection for your Personal Information as does the United States. However, Openfolio will at all times treat your Personal Information in accordance with this Privacy Policy.

California Residents

If you are a California resident, you are entitled to request certain information regarding our disclosure of Personal Information to third parties for such third parties’ direct marketing purposes. To request such a notice, please contact Openfolio Support.

 

Updates to this Policy

We may change this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we will post those changes through a prominent notice on the Services or notify you directly. We encourage you to review the Privacy Policy section each time you access the Services.

Contact Us

 

If you have any questions regarding our privacy practices, you can contact Openfolio Support. You may also write to us at:

510 Madison Ave,
Floor 21,
New York, NY 10022