Privacy Policy

Last updated 2023 October 17

Dynamic Data Strategies LLC d/b/a OpenFinancial.co ("Company" "we" or "our") is committed to advising you of the right to your privacy, and strives to provide a safe and secure user experience. This Privacy Policy explains how we collect, store and use personal information, provided by you on our website. By accessing and using our website, you explicitly accept, without limitation or qualification, the collection, use and transfer of the personal information provided by you in the manner described in this Privacy Policy. Please read this Policy carefully, as it affects your rights and liabilities under the law. If you disagree with the way we collect and process personal information, please do not use this website.

1. Information You Provide and We Collect

We collect general types of information about you when you visit and use our website; examples include personal information, demographic information, behavioral information, and indirect information. Sometimes we collect combinations of these types of information.

1.1. “Personal information” is information that can be used to identify you or any other individual to whom the information may relate. This is information which you are prompted to provide to us. Such information may include your name, address, telephone number(s), mobile numbers and email address, credit card number(s), bank account(s), or other unique information about you which you provide to us during the registration process, or though the course of communicating with us about the products and services provided on our website. We may collect this same information about all other persons when you provide it to us.

1.2. “Demographic information” is information that may or may not be unique to you in the sense that it refers to selected population characteristics. Such information may include, but is not limited to, zip code, mobile phone carrier, age, gender, salary range, education and marital status, occupation, industry of employment, personal and online interests.

1.3. “Behavioral information” is information which is automatically collected pertaining to how you use our website, the areas of our website that you visit, what services you access, and information about your computer hardware and software, including your IP address, geographic location, browser preference, operating system type, domain names, times that you access the internet, and other websites you have visited.

1.4. “Third party information” is information about you that we acquire from a third party which may include personal, demographic, behavioral and indirect information. This collection may include, but not limited to, first party cookies, third party cookies, anonymous cookies, persistent identifiers, email opt in, and search engine keywords. We have no access or control over these cookies and other tracking devices used by third party advertisers and networks. We have no responsibility or liability for the policies and practices of these parties.

1.5. “Web technology information” is information we automatically collect from you when you visit our website. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. This information is collected from the use of cookies, web beacons, pixel tags, log files, local storage, and other similar mechanisms to automatically collect information.

1.6. No Information Collected from Children. We will never knowingly collect any Personal Information from children under the age of 13. If we obtain actual knowledge that we have collected Personal Information about a child under the age of 13, that information will be immediately deleted from its database. Because it does not collect such information, we have no such information to use or to disclose to third parties.

2. Collection of Information by Web Technologies.

2.1 Generally, we as well as third party vendors and supporting advertisers use technologies such as cookies, web beacons, pixel tags, log files, local storage and similar mechanism to automatically collect information when you visit and use our website. These technologies collect internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. This information is used to analyze trends, administer our website, track a user’s movements through our website and gather demographic information about our entire user base. We may receive reports based on these technologies on an individual or aggregated basis.

(i) Cookies. “Cookies” are a feature in your browser software. If enabled, cookies store small amounts of data on your computer about actions you take on the pages of our website. Cookies assist us in tracking which of our features you visit most often, and what content you viewed on past visits. When you visit this website again, cookies allow us to remember you’re your settings and may be used for authentication. We may use cookies to keep track of the number of return visits, accumulate and aggregate statistical information generally pertaining to our website, and deliver specific content to you based on your past viewing history. You can disable cookies, although our website may not function properly for you. Your browser preferences can be modified to accept or reject all cookies, or request a notification when a cookie is set. You may read more about cookies at http://cookiecentral.com. In order to use all of the features and functionality of our website, you need to accept cookies.

(ii) Third Party Cookies. We allow third party vendors and advertisers to set their own cookies on and through our website. We have no control over the practices of those third parties and are not responsible for their technology or tracking. We encourage you to review the policies of such persons or entities on their websites. We use AdWords Remarketing through Google which is a Remarketing and Behavioral Targeting service provided by Google Inc. that connects the activity on our website with the AdWords advertising network and the DoubleClick cookie. That Cookie collects information regarding certain patterns in your browsing history. To opt-out of this tracking, please see https://support.google.com/ads/answer/2662922?hl=en. We also participate in all of Google Analytics Advertising. This includes (i) Remarketing with Google Analytics; (ii) Google Display Network Impression Reporting; (iii) DoubleClick Campaign Manager integration; and (iv) Google Analytics Demographics and Interest Reporting. Google uses cookies to track activity performed by Google Analytics and its AdWords or DoubleClick cookie. To opt-out please see https://tools.google.com/dlpage/gaoptout/. We also use Google Analytics which is an analysis service also provided by Google Inc. Google utilizes the data collected through its cookies to track and examine the use of this site, to prepare reports on its activities, and to share them with other Google services. You may opt-out of the Google Analytics service using Google’s Browser Add-available at https://tools.google.com/dlpage/gaoptout/.

(iii) Social Media Cookies. : Our website includes social media features. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing it.

2.2. Web Beacons. We use electronic images known as Web Beacons (sometimes called single-pixel gifs, clear gifs or action tags) which allow us to collect information about your visit to our website, measure and improve the effectiveness of advertisements and track delivery of advertising. Web Beacons collect only a limited set of information including a cookie number, time and date of page view, as well as a description of the page on which the Web Beacon resides. We may also use Web beacons in email messages sent to you. This allows us to determine if you opened or acted upon the email messages. Because Web beacons are the same as any other content request, you cannot opt out or refuse them. However, they can be rendered ineffective by either opting out of cookies or changing the cookie setup in your browser.

2.3. Social Media Sharing. You may be given the opportunity to register with us via third party accounts such as Facebook. These services will authenticate your identity and may provide you the option to share certain information (such as your name and email address) with us. We may store the information you provide us through such accounts and combine it with other information, including Personal Information. Disabling your Facebook or other such account may not terminate your account with us. Our services may also include social media features, such as sharing widgets provided by Facebook, Twitter, Google and Pinterest. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy policy of the company providing them.

3. How We Use Information Collected.

3.1. Providing Services and Products. We use the information we gather on our website to provide you with the services and or products you have requested. This may include passing your information on to a third party to provide such services or products. We do not control the privacy practices of these third parties. If you have any questions or wish to remove your information from the third party databases, you will need to contact that party directly.

3.2. Improving Our Website. We use the information we gather to respond to any inquires you make, operate and improve the functionality of our website, and deliver the products and services advertised on our website. Our services include the display of personalized products, content, and advertising, relating to your experience and interests. In addition, we use this information to comply with all legal obligations and resolve any disputes or concerns you may have.

3.3 Marketing. We also use the information you provide to us to send you advertisements, promotions and content by third parties that we think will be of interest to you. To provide this service we may anonymize and aggregate information for different purposes which include traffic flow, analysis usage, product development, market analysis, reports and other insights.

4. Disclosure of Information to Others.

4.1. We will share your personal information with third parties only in the ways that are described in this privacy policy.

(i.) Product and Service Delivery. We share your information with third parties who help us in the delivery of the products and services you have requested.

(ii.) Website Functionality. We share your information with companies and individuals we employ to perform technical functions on our behalf. Examples include third parties who host our website, analyze our data, provide marketing assistance, process credit card payments, and provide customer service.

(iii) Third Party Products and Services. We share your information with third parties who will provide you with their opportunities, products or services. This includes your personal and non-personal information, and includes your interests and preferences, so they may determine whether you might be interested in their products or services.

Our partners may link the nonpersonal information we share with them to the cookie stored on your browser or device, and they may collect information such as your IP address, browser or operating system type and version, and demographic or inferred-interest information. Our partners use this information to recognize you across different channels and platforms over time for advertising, analytics, attribution, and reporting purposes. To learn more about interest-based advertising in general and to opt out, please visit https://aboutads.info/choices.

(iv.) Anonymous information. We share aggregated anonymous information about you, combined with other persons using our website with third parties, so that they can understand the kinds of visitors that come to our website, and how those visitors use our website. This includes demographic information and behavioral information.

(v.) Legal Process. We disclose your information if legally required to do so, or at our discretion, pursuant to a request from a governmental entity, or if we believe in good faith that such action is necessary to (a) conform to legal requirements or comply with legal process; (b) protect our rights or property, or our affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public.

(vi.) Acquisition or Merger. We may disclose and transfer your information to a third party who acquires any or all of our business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets. In the event we become the subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of, such information in a transaction approved by the court.

5. Third Party Collection and Use of Information.

5.1. Third parties collect and use information about you on or through our website in the following way:

(i) Advertisers. Advertising agencies, advertising networks, and other companies who place ads on our website, may use their own cookies, Web beacons, and other technology, to collect information about you. We do not control the use of such technology and have no responsibility for the use of such technology to gather information about you.

(ii) Hyperlinks. Our website and email messages sometimes contain hypertext links to websites owned by third parties. We are not responsible for the privacy practices or the content of such other websites. These links are provided for your convenience and reference only. We do not operate or control any information, software, products or services, available on these third party websites. The inclusion of a link on our website does not imply any endorsement of the services, products or website, or its sponsoring organization.

(iii) Scripts. We use certain scripts provided by third-party service providers, such as those provided by Lead Intelligence, Inc. d/b/a Jornaya (“Jornaya”), ActiveProspect, Inc. (including its TrustedForm service) and Microsoft Clarity, to independently document users’ consent to be contacted, including those users’ "prior express consent" has been provided as required by the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time ("TCPA"). These scripts are embedded on our website and collect the following information when users interact with the page(s) where the scripts are present: page URL, mouse movements and clicks, contact information inputted by the user, a snapshot of the page, including IP address of the user’s computer, time on the page, date and time that the script was loaded, as well as the date and time of the various user interactions with the page, and HTTP headers from the user’s browser. For more information about the data usage, retention and collection policies and practices of these third-party service providers, please click on the links located below:

ActiveProspect Trusted Form Script. Privacy Policy: https://activeprospect.com/privacy-policy
Microsoft Clarity’s Script. Privacy Policy: https://privacy.microsoft.com/en-us/privacystatement
Jornaya’s Script. Privacy Policy: https://www.jornaya.com/consumer-privacy-policy/

(iiii) Analytics. As described above, we use third parties to monitor analyze and report on the traffic to, from and within our website and email messages.

6. Security.

We endeavor to safeguard and protect your information. When you submit information on our website, such information is protected both online and offline. We have security measures in place to protect against the loss, misuse, and alteration of personal information under our control. The servers in which we store your information are kept in a secure physical environment. The servers have industry standard firewalls. Access to such servers is password protected and access by our employees is limited. Currently, we use Secure Socket Layer software ("SSL") to protect data and to secure any transactions. SSL encrypts information including credit card number(s), and names and addresses, as they are transmitted over the Internet. Please be advised that, although we take commercially reasonable technological precautions to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure; therefore, we cannot and do not warrant that your information will be absolutely secure. Any transmission of data at or through our website is at your own risk. However, access to your information is strictly limited and not accessible to the public.

7. Changes to Privacy Policy.

We reserve the right to make material changes to the substance of this Privacy Policy. We will post those changes through a prominent notice on the website, so that you will always know what information we gather, how we might use that information, and to whom we will disclose it.

8. Your California Rights.

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the personal information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. If you are a California resident and want a copy of this information, please submit a written request to us at 228 Park Ave S Suite #77649, New York, NY 10003-1502. In your request, please specify that you want a “Your California Privacy Rights Notice.” Please allow 30 days for a response. In addition, California residents have the right to know if we respond to do not track signals or cookies. We do not respond to such signals or cookies.

CONTACT US
If you have any questions regarding this Privacy Policy, please contact:
OpenFinancial.co
427 N Tatnall St #77649
Wilmington, Delaware 19801-2230 contact@openfinancial.co
(424) 772-3508

Privacy Policy for California Residents

This Privacy Notice for California Residents supplements the information contained in our privacy policy above and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). We have collected the following categories of personal information from consumers within the last twelve (12) months:

Categories	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

Public information does not include:

Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:

health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you.
Indirectly from you. For example, through information we collect from our clients in the course of providing services to them.
Directly and indirectly from activity on our website.
From third-parties that interact with us in connection with the services we perform.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

To fulfill or meet the reason for which the information is provided.
To provide you with information, products or services that you request from us.
To provide you with email alerts.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
To improve our website and present its contents to you.
For testing, research, analysis and product development.
As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers. Category B: California Customer Records personal information categories.

We disclose your personal information for a business purpose to the following categories of third parties:

Our affiliates.
Service providers.
Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
Third party marketers who we feel you will benefit from their services.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

b You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

sales, identifying the personal information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at 424-772-3508
Visiting OpenFinancial.co
By clicking here and filling out the form. If the link doesn't work, you can copy and paste this url https://openfinancial.co/ccpa into your browser.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 424-772-3508
Website: OpenFinancial.co
Email: contact@openfinancial.co
Postal Address: OpenFinancial.co
427 N Tatnall St #77649
Wilmington, Delaware 19801-2230