Open-i Advisors, Inc. Privacy Policy

Effective 4/24/2018

Scope:

Open-i Advisors has developed the following privacy policy to protect individually identifiable information. This policy covers Open-i Advisors and applies to all individually identifiable information that Open-i Advisors obtains when a client engages Open-i Advisors, including both for custom consulting and the report services.

Open-i Advisors protects individually identifiable information as follows:

Disclosure:

Open-i Advisors will not sell, trade, or disclose to third parties any individually (either client or Open-i Advisors employee) identifiable information, derived from the any Open-i Advisors engagement, (except as required by subpoena, search warrant or other legal process or in the case of imminent physical harm to the customer or others). When Open-i Advisors uses other agents, contractors or companies to perform services on its behalf, Open-i Advisors will ensure that the company protects the individually identifiable information consistent with this policy

Security:

Open-i Advisors has implemented technology and security features and strict policy guidelines to safeguard the privacy of identifiable information from unauthorized access or improper use, and we will continue to enhance our security procedures as new technology becomes available.

E-Mail Contents:

The company will not read or disclose to third parties private e-mail communications that are transmitted using Open-i Advisors services except as required to operate the service or as otherwise authorized by law.

Improper Conduct:

Open-i Advisors may use individually identifiable information to investigate and help prevent potentially unlawful activity or activity that threatens the network or otherwise violates the customer agreement for that service.

Account Information:

Open-i Advisors honors requests from clients for changes in account information, such as name and email address, and will correct any such information that is inaccurate. Open-i Advisors honors requests from clients for swift correction, amendment, or deletion of all stored client data upon request.

EU-U.S. Privacy Shield:

The United State Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (FAQ) to enable U.S. companies to satisfy European Union (EU) law requirements for adequate protection of personal information transferred from the EEA to the United States.  Open-i Advisors Inc. adheres to the EU-U.S. Privacy Shield Principles outlined below.

Privacy Principles:

The privacy principles in this policy are based on the EU-U.S. Privacy Shield Principles.

Notice and Choice:

Open-i Advisors Inc. does not collect personal information directly from individuals in the EU.  Personal information may exist in information that is provided to Open-i Advisors Inc, from an EEA organization for processing.  To the extent permitted in the EU-U.S. Privacy Shield Agreement, we reserve the right to process personal information in the course of providing consulting services to our clients without the knowledge of individuals involved.

Onward Transfers and Disclosures to Agents:

Open-i Advisors Inc. will not knowingly disclose an individual’s personal information to third parties, except when one or more of the following conditions is true:

  •    We have the individual’s permission to make the disclosure.
  •    The disclosure is required by law or professional standards.
  •    The information is question is publicly available.
  •    The disclosure is reasonably necessary for the establishment or defense of legal claims.

Data Security:

Open-i Advisors Inc takes data security seriously and has put in place appropriate physical, electronic, and procedures to safeguard and secure the information we process.

Data Integrity:

Open-i Advisors Inc. will use personal information only in ways that are compatible with the purposes for which it was collected.

Access:

Upon request, Open-i Advisors Inc. will grant individuals reasonable access to personal information that it holds about them.  In addition, Open-i Advisors Inc. will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

Enforcement:

Open-i Advisors Inc. utilizes the self-assessment approach to assure its compliance with our privacy statement.  Open-i Advisors Inc. periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the EU-U.S. Privacy Shield Principles

Changes in Practices: Open-i Advisors will keep this policy current and will inform you of any changes that we make.