We value your privacy
Last Modified: May 7, 2019
Decentralized Securities Depository, LLC, d/b/a OpenFinance Network, CFX Direct, LLC and Sageworks Capital, LLC (collectively, "OFN," "we," "our," or "us") respect your privacy and are committed to protecting it through our compliance with this policy.
This policy applies to information we collect:
It does not apply to information collected by:
For information about how we collect, use, and share your financial information, please refer to our Financial Privacy Notice.
OFN is the data controller of the Personal Data you provide on the Websites. At this time, OFN does not have a Data Protection Officer or EU representative.
Our Websites are not intended for children under the age of 18 and children under the age of 18 are not permitted to use our Websites. We will remove any information about a child under the age of 18 if we become aware of it.
Our Websites are not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on the Websites. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Websites or on or through any of its features/register on the Websites, make any purchases through the Websites, use any of the interactive or public comment features of our Websites or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18, please contact us by email at email@example.com or by visiting the “Contact Us” section of the “Support” page of our Websites.
We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.
We collect several types of information from and about users of our Websites (“Personal Data”):
We collect this information:
Information You Provide to Us
The information we collect on or through our Websites are:
The Personal Data we collect from you is required to enter into a contract with OFN, for OFN to perform under the contract, and to provide you with our products and services. If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data, then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it.
IInformation We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Websites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns:
The information we collect automatically may include Personal Data, or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Websites and to deliver a better and more personalized service by enabling us to:
We have a lawful basis for our processing of your Personal Data, including processing for our legitimate interests (when balanced against your rights and freedoms), to fulfill our obligations to you under a contract with you, and required by law, and with your consent.
If you are in the European Union, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception applies as described below):
We generally do not request you provide and do not process any special categories of Personal Data.
OFN does not ask you to provide, and we do not knowingly collect, any special categories of Personal Data from you.
We may process your Personal Data with automated decision making processes. A high-level description of the algorithms we use below.
Our processing of your personal data may include automated decision making, including profiling, which may produce a legal effect concerning you or similarly significantly affect you. The algorithms used for our automated decision making are utilized in a variety of ways, including matching OFN platform users with securities which regulations provide them eligibility to trade.
We use your Personal Data for various purposes described below, including to:
We use information that we collect about you or that you provide to us, including any Personal Data:
With your consent, we may also use your information to contact you about our own goods and services that may be of interest to you. If you wish to consent to this use, please check the relevant box located on the form on which we collect your data. If you wish to change your choice, you may do so at any time by logging into the Websites and adjusting our user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request at firstname.lastname@example.org. For more information, see Choices About How We Use and Disclose Your Information.
We may also disclose your Personal Data:
We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for third-parties to advertise to you, our advertising to you, and other targeted advertising.
We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.
In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:
You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info). We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.
You may have certain rights under applicable data protection laws, including the right to access and update your Personal Data, restrict how it is used, transfer certain Personal Data to another controller, withdraw your consent at any time, and the right to have us erase certain Personal Data about you. You also have the right to complain to a supervisory authority about our processing of your Personal Data.
Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data.
We currently do not honor do-not-track signals that may be sent by some browsers.
We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.
Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Websites confidential.
We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Websites. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites.
We may process your Personal Data outside of your home country, including to the United States. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your Personal Data.
If you are a resident of the European Economic Area (“EEA”), in order to provide our Websites, products, and services to you, we may send and store your Personal Data outside of the EEA, including to the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data.
We retain your Personal Data for as long as you keep your account open. In some instances, we may keep it after you close your account, for example we may keep it:
OFN will retain your Personal Data for the entire time that you keep your account open. After you close your account, we may retain your Personal Data:
You may contact us through the contact information below or through the “Help” page on our Websites.
Additional Contact Information for OFN
Attn: OpenFinance Network - User Support
222 W. Merchandise Mart Plaza
Chicago, IL 60654