Last updated August 11, 2022

This privacy notice for Opal Financial Group, Inc. “Opal Connect Project” (doing business as Opal Group / Opal Connect) (“Company,” “we,” “us,” or “our“) describes how and why we might collect, store, use, and share (“process“) your information when you use our services (“Services“), such as when you:

• Visit our website at opalconnect.net or any website of ours that links to this privacy notice
• Visit our website at opalgroup.net or any website of ours that links to this privacy notice
• Engage with us in other related ways ― including any sales, marketing, networking, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you disagree with our policies and practices, please do not use our Services. If you still have questions or concerns, please contact us at info@opalconnect.net.

Summary of Key Points

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Opal Group, Opal Connect, the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal information. / We may process sensitive personal information, when necessary, with your consent or as permitted by applicable law.

Do you receive any information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources.

How do you process my information? We process your information to provide, improve, and administer our Services, communicate with you for security and fraud prevention, and comply with the law. We may also process your information for other purposes with your consent. We process your data only when we have a valid legal reason.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. However, the data would only be shared within the platform. We will not share the information for any reason other than Opal Connect.

• Your headshot, name, company name, position and title, user activity, AUM (Assets Under Management), and areas of interest will be provided to build partnerships through networking and estimate project costs.
• Based on the areas of interest defined by Opal’s platform, your profile would be visible to others who share your interests.
• Location information: country, city, and state.

How do we keep your information safe? We have organizational and technical processes and procedures to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. However, we take all reasonable measures to ensure your privacy and security.

What are your rights? Where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do I exercise my rights? The easiest way to exercise your rights is by sending an email to: info@opalconnect.net or by contacting us. We will consider and act upon any request by applicable data protection laws.

Want to learn more about what Opal Group / Opal Connect does with any information we collect?

Table of Contents

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
9. HOW LONG DO WE KEEP YOUR INFORMATION?
10. HOW DO WE KEEP YOUR INFORMATION SAFE?
11. DO WE COLLECT INFORMATION FROM MINORS?
12. WHAT ARE YOUR PRIVACY RIGHTS?
13. CONTROLS FOR DO-NOT-TRACK FEATURES
14. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
15. DO WE MAKE UPDATES TO THIS NOTICE?
16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

The personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Opal Connect platform, express an interest in obtaining information about us or our products and Services, participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information we collect depends on the context of your interactions with the Services and us, your choices, and the products and features you use. The personal information we collect may include the following:

• Full Name
• Job Title
• Phone number
• Picture
• Time Zone,
• Job details
  • Organization Name
  • Company Type
  • Phone Number
  • Website
  • Organization Description
  • Organization Logo
  • Social media information
  • Financial information
  • Company interests
• Address
  • Region
  • Country
  • State
  • City
  • Zip Code
  • Address
• Other
  • Services provided

Sensitive Information. We do not process sensitive information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• Detailed financial information.
• Total AUM Assets Under Management
• Total fund value
• Inception date
• Financial category

Payment Data. We may collect data necessary to process your payment if you pay for a subscription, such as your payment instrument number (debit or credit card number 16 digits) and the security code associated with your payment instrument. Your personal name stores all payment data.

Social Media Login Data. We may allow you to register with us using your existing social media account details, like your Facebook, Twitter, LinkedIn, or other social media accounts. If you choose to write this way, we will collect the information described in the section “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below.

Platform Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Geolocation Information. We may request access or permission to track location-based information from your mobile device continuously or while you are using our mobile application(s) to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s Bluetooth, calendar, camera, own, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information, system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider, and mobile carrier, and Internet Protocol (IP) address (or proxy server). Suppose you are using our application(s). In that case, we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.
• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt-out of receiving these types of communications, you may turn them off in your device’s settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and our internal analytics and reporting purposes.

All personal information you provide must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information). Still, it may include device and usage information, such as your IP address, browser, device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical details. This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes

• Log and Usage Data. Log and usage data are service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services, which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages, and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or another device you use to access the Services. Depending on the device used, this data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and mobile carrier, operating system, and system configuration information.
• Location Data. We collect location data, such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt-out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt-out, you may not be able to use certain aspects of the Services.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

To enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles for purposes of targeted advertising and event promotion. Suppose you interact with us on a social media platform using your social media account (e.g., Facebook or LinkedIn). In that case, we receive personal information about you, such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account’s privacy settings.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you for security and fraud prevention, and comply with the law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account and keep your budget in working order.
• To deliver and facilitate the delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your questions and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To fulfill and manage your orders. We may process your information to execute and manage your orders, payments, returns, and exchanges through the Services.
• To enable user-to-user communications. We may process your information if you use our offerings to communicate with another user.
• To request feedback. We may process your information when necessary to request feedback and contact you about using our Services.
• To send you marketing and promotional communications. We may process the personal information you send us for our marketing purposes if this is by your marketing preferences. You can opt-out of our marketing emails at any time. For more information, see “WHAT ARE YOUR PRIVACY RIGHTS?” below).
• To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more. For more information, see our Cookie Notice: [Cookie Notice URL].
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to understand better how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to understand better how to provide marketing and promotional campaigns that are most relevant to you.
• To save or protect an individual’s vital interest. We may process your information when necessary to keep or cover an individual’s strong interest and prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

This section applies to you if you are in the EU or UK.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the suitable legal bases we rely on to process your personal information. As such, we may depend on the following legal grounds to process your personal information:

• Consent. We may process your information if you have permitted us (i.e., consent) to use your data for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request before entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is necessary to achieve our legitimate business interests. Those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described:
  • Send users information about special offers and discounts on our products and services
  • Develop and display personalized and relevant advertising content for our users
  • Analyze how our services are used so we can improve them to engage and retain users
  • Support our marketing activities
  • Diagnose problems and prevent fraudulent activities
  • Understand how our users use our products and services so we can improve user experience
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

In legal terms, we are generally the “data controller” under European data protection laws of the personal information described in this privacy notice since we determine the means and purposes of the data processing we perform. This privacy notice does not apply to the personal information we process as a “data processor” on behalf of our customers. In those situations, the customer we provide services to and with whom we have entered into a data processing agreement is the “data controller” responsible for your personal information. We merely process your information on their behalf per your instructions. To know more about our customers’ privacy practices, you should read their privacy policies and direct any questions you have to them.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your data for a particular purpose or in situations where your authorization can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions, provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess the process or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is or may be a victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information, and the collection is suitable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If an individual produced it in the course of their employment, business, or profession, and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means they cannot do anything with your personal information unless we have instructed them. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:

• Ad Networks
• Data Analytics Services
• Data Storage Service Providers
• Order Fulfillment Service Providers
• Payment Processors
• Performance Monitoring Tools
• Product Engineering & Design Tools
• Sales & Marketing Tools
• Testing Tools
• User Account Registration & Authentication Services
• Website Hosting Service Providers

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• When we use Google Maps Platform APIs. We may share your information with specific Google Maps Platform APIs (e.g., Google Maps API, Places API). To find out more about Google’s Privacy Policy, please refer to this link. We use specific Google Maps Platform APIs to retrieve certain information when you make location-specific requests. This includes [List of Information Collected] and other similar information. This section and the previous section titled “HOW DO WE PROCESS YOUR INFORMATION?” is a complete list of what we use the information for. [We obtain and store on your device (‘cache’) your location for [#] You may revoke your consent anytime by contacting us at the contact details provided at the end of this document. We use the Google Maps Platform APIs to store and access cookies and other information on your devices. If you are a user currently in the European Economic Area (EU countries, Iceland, Liechtenstein, and Norway) or the United Kingdom, please take a look at our Cookie Notice, which can be found at this link: [Cookie Notice URL].
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• Business Partners. We may share your information with our business partners to offer certain products, services, or promotions.
• Other Users. When you share personal information [(for example, by posting comments, contributions, or other content to the Services)] or otherwise interact with public areas of the Services, such personal information may be viewed by all users and publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users can view your training reports, communicate with you within our Services, and view your profile.
• Offer Wall. Our application(s) may display a third-party hosted “offer wall.” Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our application(s) and be displayed based on specific data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider to prevent fraud and appropriately credit your account with the relevant reward.

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information you share with third parties that we may link to or advertise on our Services but are not affiliated with.

The Services may link to third-party websites, online services, or mobile applications and contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not guarantee any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. Including a link to a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to third parties. This privacy notice does not cover any data collected by third parties. We are not responsible for any third parties content, privacy, security practices, or policies, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies to access or store information.

7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Google logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider but will often include your name, email address, friends list, profile picture, and other information you choose to make public on such a social media platform. If you log in using Facebook, we may also request access to additional permissions related to your accounts, such as your friends, check-ins, and likes, and you may choose to grant or deny us access to each license.

We will use the information we receive only for the purposes described in this privacy notice or otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend you review their privacy notice to understand how they collect, use and share your personal information and how you can set your privacy preferences on their sites and apps.

8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than yours.

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information.

Suppose you are a European Economic Area (EEA ) or UnitEEAgdom (UK) resident. In that case, these countries may not necessarily have data protection laws or similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information by this privacy notice and applicable law.

European Commission’s Standard Contractual Clauses:

We have implemented measures to protect your personal information, including using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and our third-party providers. These clauses require all recipients to protect all personal information they process from the EEA or UK by European data protection laws and regulations. Our Data Processing Agreements that include Standard Contractual Clauses are available here: [Standard Contractual Clauses URL]. We have implemented similar appropriate safeguards with our third-party service providers and partners, and further details can be provided upon request.

EU-US and Swiss-US Privacy Shield Framework.

Opal Financial Group, Inc. “Opal Connect” comply with the EU-US and Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (EU), the UK, and Switzerland to the United States. Although Privacy Shield is no longer considered a valid transfer mechanism for EU and Swiss data protection law, in light of the judgment of the Court of Justice of the European Union in Case C-311/18 and the opinion of the Federal Data Protection and Information Commissioner of Switzerland dated 8 September 2020, Opal Financial Group, Inc. “Opal Connect” will continue to comply with the principles of the EU-US and Swiss-US Privacy Shield Framework.

Opal Financial Group, Inc. “Opal Connect” adheres to and complies with the Privacy Shield Principles when processing personal information from the EU, UK, or Switzerland. If we have received your personal information in the United States and subsequently transferred that information to a third party acting as our agent. Such a third-party agent processes your personal information in a manner inconsistent with the Privacy Shield Principles; we will remain liable unless we can prove we are not responsible for the event giving rise to the damage.

Concerning personal information received or transferred under the Privacy Shield Framework, Opal Financial Group, Inc. “Opal Connect” is subject to the investigatory and enforcement powers of the US Federal Trade Commission (“FTC”). In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

9. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice unless a more extended retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will need us to keep your personal information for longer than the period users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such data or, if this is impossible (for example, because your personal information has been stored in backup archives). We will securely store your personal information and isolate it from any further processing until deletion is possible.

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, the transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

11. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18.

We do not knowingly solicit data from or market to children under 18. By using the Services, you represent that you are at least 18 or the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to delete such data from our records promptly. If you become aware of any data we may have collected from children under 18; please contact us at info@opalconnect.net.

12. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

You have certain rights under applicable data protection laws in some regions (like the EEA, UK, and Canada). These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, and (iv), if applicable, to data portability. In certain circumstances, you may also have the right to object to processing your personal information. You can make such a request by contacting us using the contact details provided in the “HOW CAN YOU CONTACT US ABOUT THIS NOTICE section?” below.

We will consider and act upon any request by applicable data protection laws.

Suppose you are located in the EEA or UK, and you believe we are unlawfully processing your personal information. In that case, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we rely on your support to process your personal information, which may be express and implied, depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent anytime by contacting us using the contact details provided in the “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below or by updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications:  You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying “STOP” or “UNSUBSCRIBE” to the email messages that we send, or by contacting us using the email info@opalconnect.net. You will then be removed from the marketing lists. However, we may still communicate with you, for example, to send you service-related messages necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.
• Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some data in our files to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms, and comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and reject cookies. If you remove or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at info@opalconnect.net.

13. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers, mobile operating systems, and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference and not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

14. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal data (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request the removal of unwanted data that you publicly post on the Services. Please get in touch with us using the information provided below to ask for the removal of such data. Include the email address associated with your account and a statement that you reside in California. We will ensure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

We may also collect other personal information outside of these categories in instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation the delivery of our Services and respond to your inquiries.

How do we use and share your personal information?

Opal Financial Group, Inc. “Opal Connect” collects and shares your personal information through:

• Targeting cookies/Marketing cookies
• Social media cookies
• Beacons/Pixels/Tags
• Click redirects: [Click Redirects]

You may contact us by email at info@opalconnect.net, by calling 212-532-7151, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers under a written contract between each service provider and us. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for business purposes, such as undertaking internal research for technological development and demonstration. This is not considered the “selling” of your personal information.

Opal Financial Group, Inc. “Opal Connect” has disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

• Category A. Identifiers include contact details like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.
• Category B. Personal information, as defined in the California Customer Records law, includes your name, contact information, education, employment, employment history, and financial information.
• Category C. Characteristics of protected classifications under California or federal law, such as gender or date of birth.
• Category D. Commercial information, such as transaction information, purchase history, financial details, and payment information.
• Category E. Other company information.
• Category F. Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.
• Category G. Geolocation data, such as device location.
• Category H. Audio, electronic, visual, and similar information, such as images and audio, video, or call recordings created in connection with our business activities.
• Category I. Professional or employment-related information, such as business contact details, to provide you with our services at a business level or job title, work history, and professional qualifications if you apply for a job with us.
• Category J. Education information, such as student records and directory information.
• Category K. Inferences are drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”.

Opal Financial Group, Inc. “Opal Connect” has not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Opal Financial Group, Inc. “Opal Connect” has sold the following categories of personal information to third parties in the preceding twelve (12) months:

• Category A. Identifiers, such as contact details, like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.
• Category B. Personal information, as defined in the California Customer Records law, includes your name, contact information, education, employment, employment history, and financial information.
• Category C. Characteristics of protected classifications under California or federal law, such as gender or date of birth.
• Category D. Commercial information, such as transaction information, purchase history, financial details, and payment information.
• Category E. Biometric information, such as fingerprints and voiceprints.
• Category F. Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.
• Category G. Geolocation data, such as device location.
• Category H. Audio, electronic, visual, and similar information, such as images and audio, video, or call recordings created in connection with our business activities.
• Category I. Professional or employment-related information, such as business contact details, to provide you with our services at a business level or job title, work history, and professional qualifications if you apply for a job with us.
• Category J. Education information, such as student records and directory information.
• Category K. Inferences are drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

The categories of third parties to whom we sold personal information are:

• Ad Networks
• Affiliate Marketing Programs
• Data Analytics Services
• Retargeting Platforms
• Social Networks
• User Account Registration & Authentication Services
• Other Financial

Your rights concerning your data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. Suppose you ask us to delete your personal information. In that case, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of their right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know.

Depending on the circumstances, you have a right to know:

• whether we collect and use your personal information;
• the categories of personal information that we collect;
• the purposes for which the collected personal information is used;
• whether we sell your personal information to third parties;
• the categories of personal information that we sold or disclosed for a business purpose;
• the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
• the business or commercial purpose for collecting or selling personal information.

By applicable law, we are not obligated to provide or delete consumer information de-identified in response to a consumer request or re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine that you are the same person with whom we have the information in our system. These verification efforts require us to ask you to provide information so we can match it with the information you previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for verification. However, suppose we cannot verify your identity from the information already maintained by us. In that case, we may request that you provide additional information to verify your identity and for security or fraud-prevention purposes. We will delete such other information as soon as we finish verifying you.

Other privacy rights

• You may object to the processing of your personal information.
• You may request correction of your data if it is incorrect or no longer relevant or ask to restrict the processing of the information.
• You can designate an authorized agent to request the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf by the CCPA.

To exercise these rights, you can contact us by email at [Email Address], by calling toll-free at [Phone Number], by visiting [Contact Form URL], or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

Financial Incentives

“Financial incentive” means a program, benefit, or other offerings, including payments to consumers for disclosing, deleting, or selling personal information.

The law permits financial incentives or a price or service difference if it is reasonably related to the value of the consumer’s data. A business must be able to explain how the financial incentive or price, or service difference is reasonably related to the value of the consumer’s data. The explanation must include:

• a reasonable faith estimate of the value of the consumer’s data that forms the basis for offering the financial incentive or price or service difference; and
• a description of the business’s method used to calculate the value of the consumer’s data.

We may decide to offer a financial incentive (e.g., price or service difference) in exchange for the retention or sale of a consumer’s personal information.

Suppose we decide to offer a financial incentive. In that case, we will notify you of such financial incentive and explain the price difference and material terms of the financial incentive or price of service difference, including the categories of personal information implicated by the financial incentive or price or service difference.

Suppose you choose to participate in the financial incentive. In that case, you can withdraw from the financial incentive at any time by emailing us at [Email Address], calling us toll-free at [Phone Number], visiting [Contact Form URL], or refer to the contact details at the bottom of this document.

Metrics

Our metrics for all CCPA requests received for the previous calendar year can be found here: [Metrics URL].

15. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date, and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you by prominently posting a notice of such changes or directly sending you a notification. We encourage you to review this privacy notice frequently to inform you how we protect your information.

16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Daniela Funes, by email at info@opalconnect.net or by phone at 212-532-7151.

If you have any further questions or comments, you may also contact us by post at the following corporate address:

Opal Financial Group
132 West 36th Street, Suite 510
New York, NY 10018

17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please email info@opalconnect.net.