At OpenBB, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and disclose your information as described in this Privacy Policy.

Remember that your use of OpenBB'S Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. Upon such changes, we will alert you to any such changes by placing a notice on the OpenBB website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven't provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

Privacy Policy Table of Contents

What this Privacy Policy Covers
Personal Data
How We Disclose Your Personal Data
Tracking Tools and Opt-Out
Data Security
Personal Data of Children
California Resident Rights ("CCPA")
Colorado Resident Rights ("CPA")
Connecticut Resident Rights ("CTDPA")
Montana Resident Rights ("MCDPA")
Oregon Resident Rights ("OCPA")
Texas Resident Rights ("TDPSA")
Utah Resident Rights ("UCPA")
Virginia Resident Rights
Exercising Your Rights under the State Privacy Laws
Other State Law Privacy Rights
Contact Information

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

Category of Personal Data	Examples of Personal Data We Collect	Categories of Third Parties With Whom We Disclose this Personal Data
Profile or Contact Data	- First and last name - Email	- Service Providers - Parties You Authorize, Access or Authenticate
Online Identifiers	- Unique identifiers such as unique user ID, account names, and passwords - Other unique personal or online identifiers	- Service Providers - Parties You Authorize, Access or Authenticate
Payment Data	- Payment card type - Last 4 digits of payment card - Bank account information - Billing address, phone number, and email	- Payment Processor Only
Commercial Data	- Purchase history (e.g. products or services, either purchased, obtained, or considered by user)	- Service Providers
Device/IP Data	- IP address - Device ID - Type of device/operating system/browser used to access the Services	- Service Providers - Analytics Partners
Web Analytics	- Browsing or search history - Web page interactions - Referring webpage/source through which you accessed the Services	- Service Providers - Analytics Partners
Application Telemetry	- Application usage data	- Service Providers - Analytics Partners
Professional or Employment-Related Data	- Professional work field (optional)	- Service Providers
Geolocation Data	- IP-address-based location information - Time Zone based location information	- Service Providers - Analytics Partners
Other Identifying Information that You Voluntarily Choose to Provide	- Identifying information in emails or letters you send us - Identifying information in files and content you uploaded to or stored in the Services - Identifying information in any User Inputs or User Submissions you voluntarily provide to us. - User encrypted API keys and unencrypted application settings.	- Service Providers - Parties You Authorize, Access or Authenticate

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You
- When you provide such information directly to us:
  - When you create an account or use our interactive tools and Services.
  - When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
  - When you voluntarily provide information as User Inputs or User Submissions to the Services.
  - When you send us an email or otherwise contact us.
- When you use the Services and such information is collected automatically:
  - Through Cookies (defined in the "Tracking Tools and Opt-Out" section below).
  - If you use a location-enabled browser, we may receive information about your location.
  - If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services.
Third Parties
- Vendors:
  - We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
  - We may use vendors to obtain information to generate leads and create user profiles.
- Social Networks/Communication Platforms:
  - If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.

Our Commercial or Business Purposes for Collecting Personal Data

Providing, Customizing and Improving the Services
- Creating and managing your account or other user profiles.
- Processing orders or other transactions; billing.
- Providing you with the products, services or information you request.
- Meeting or fulfilling the reason you provided the information to us.
- Providing support and assistance for the Services.
- Improving the Services, including testing, research, internal analytics and product development.
- Personalizing the Services, website content and communications based on your preferences.
- Doing fraud protection, security and debugging.
- Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.
Marketing the Services
- Marketing and selling the Services.
- Showing you advertisements.
Corresponding with You
- Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about OpenBB or the Services.
- Sending emails and other communications according to your preferences or that display content that we think will interest you.
Meeting Legal Requirements and Enforcing Legal Terms
- Fulfilling our legal obligations under applicable law, regulation, court order or other legal process.
- Protecting the rights, property or safety of you, OpenBB or another party.
- Enforcing any agreements with you.
- Responding to claims that any posting or other content violates third-party rights.
- Resolving disputes.

How We Disclose Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a "sale" of your Personal Data. For more information, please refer to the state-specific sections below.

Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
- Hosting, technology and communication providers.
- Security and fraud prevention consultants.
- Support and customer service vendors.
- Product fulfillment and delivery providers.
- Payment processors.
Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
- Companies that track how users found or were referred to the Services.
- Companies that track how users interact with the Services.
Business Partners. These parties partner with us in offering various services. They include:
- Companies that we partner with to offer joint promotional offers or opportunities.
Parties You Authorize, Access or Authenticate
- Third parties you access through the services.
- Social media services.
- Other users.

Legal Obligations

We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under "Meeting Legal Requirements and Enforcing Legal Terms" in the "Our Commercial or Business Purposes for Collecting Personal Data" section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not disclose such data in a manner that could identify you.

Tracking Tools and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base, and operate and improve our Services. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone, or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

Essential Cookies: Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
Functional Cookies: Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time, and recognize you when you return to our Services. These Cookies help us personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
Performance/Analytical Cookies: Performance/Analytical Cookies such as Cloudflare allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services, and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website, and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, you can access your Cookie management settings by clicking [LINK]. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

Data Security

We seek to protect your Personal Data from unauthorized access, use, and disclosure using appropriate physical, technical, organizational, and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanisms; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Data Retention

We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

For example:

We retain your profile information and credentials for as long as you have an account with us.
We retain your payment data for as long as we need to process your purchase or subscription.
We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively, and efficiently.

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at support@openbb.co.

California Resident Rights

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights under the State Privacy Laws” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@openbb.co.

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

The categories of Personal Data that we have collected about you.
The categories of sources from which that Personal Data was collected.
The business or commercial purpose for collecting or selling your Personal Data.
The categories of third parties with whom we have disclosed your Personal Data.
The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data disclosed with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.

You may request the above information beyond the 12 month period, but no earlier than January 1, 2022. If you do make such a request, we are required to provide that information unless doing so proves impossible or would involve a disproportionate effort.

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested or if deletion of your Personal Data involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Correction

You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.

Personal Data Sales and Shares Opt-Out

We will not sell or share your Personal Data, and have not done so over the last 12 months. To our knowledge, we do not sell or share the Personal Data of minors under 16 years of age.

Limit the Use of Sensitive Personal Information

We collect Personal Data that is considered “Sensitive Personal Information” under the CCPA. Because we use or disclose Sensitive Personal Information for purposes of inferring characteristics and/or for purposes other than those set forth in section 7027(m) of the CCPA regulations, California residents have the right to request that we limit the use or disclosure of their Sensitive Personal Information (“Right to Limit”). To exercise your Right to Limit, please follow the instructions in the “Exercising Your Rights under State Privacy Laws” section.

The Right to Limit allows California residents to direct a business that collects Sensitive Personal Information to limit its use of this information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services, to perform the services set forth in paragraphs (2), (4), (5), and (8) of subdivision (e) of Section 1798.140, and as authorized in the CCPA regulations.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Colorado Resident Rights

If you are a Colorado resident, you have the rights set forth under the Colorado Privacy Act (“CPA”). Please see the “Exercising Your Rights under the State Privacy Laws” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Colorado resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@openbb.co.

Access

You have the right to request confirmation of whether or not we are processing your Personal Data and to access and request a copy of your Personal Data in a machine-readable format, to the extent technically feasible, twice within a calendar year.

Correction

You have the right to correct inaccuracies in your Personal Data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Data.

Deletion

You have the right to delete Personal Data concerning you.

Personal Data Sales and Targeted Advertising Opt-Out

We do not currently sell or process for the purposes of targeted advertising your Personal Data as defined under the CPA (“Targeted Advertising”).

Profiling Opt-Out

We do not process your Personal Data for ‘Profiling’ to make ‘Decisions’ under the CPA. ‘Profiling’ means any form of automated processing performed on personal data to evaluate, analyze, or predict personal aspects related to an identified or identifiable individual's economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. ‘Decision’ means any ‘Decisions that produce legal or similarly significant effects concerning a Consumer,’ as defined in the CPA that concern you.

Consent or “Opt-in” Required and How to Withdraw

We may seek your consent to collect or process certain Personal Data, including: 1) Sensitive Data, 2) Personal Data from a known child under 13 years of age, 3) to sell or process Personal Data for Targeted Advertising or Profiling after you exercise your right to opt-out, or 4) Personal Data for Secondary Use.

If you would like to withdraw your consent, please follow the instructions under the “Exercising Your Rights under State Privacy Laws” section.

We Will Not Discriminate Against You

We will not process your personal data in violation of state and federal laws that prohibit unlawful discrimination against consumers.

Connecticut Resident Rights

If you are a Connecticut resident, you have the rights set forth under the Connecticut Data Privacy Act (“CTDPA”). Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Connecticut resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@openbb.co.

Access

You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.

Correction

Deletion

You have the right to delete Personal Data you have provided to us or we have obtained about you.

Portability

You have the right to request a copy of your Personal Data that is processed automatically in a machine-readable format, to the extent technically feasible.

Personal Data Sales and Targeted Advertising Opt-Out

We do not currently sell or process for the purposes of targeted advertising your Personal Data as defined under the CTDPA.

We do not sell or process for the purposes of targeted advertising the Personal Data of minors under 13 years of age.

Profiling Opt-Out

We do not process your Personal Data for ‘Profiling’ as defined under the CTDPA. ‘Profiling’ means any form of automated processing performed on personal data to evaluate, analyze or predict personal aspects related to an identified or identifiable individual's economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

Consent or “Opt-in” Required and How to Withdraw

We may seek your consent to collect or process certain Personal Data, including: 1) Sensitive Data, 2) Sensitive Data from a known child under 13 years of age, or 3) to sell, or process Personal Data for Targeted Advertising, if you are at least 13 years old but younger than 16 years old.

If you would like to withdraw your consent, please follow the instructions under the “Exercising Your Rights under State Privacy Laws” section.

We Will Not Discriminate Against You for Exercising Your Rights Under the CTDPA

We will not discriminate against you for exercising your rights under the CTDPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CTDPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CTDPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Montana Resident Rights

If you are a Montana resident, you have the rights set forth under the Montana Consumer Data Privacy Act (“MCDPA”). Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Montana resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@openbb.co.

Access

You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.

Correction

Portability

You have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.

Deletion

You have the right to delete Personal Data you have provided to us or we have obtained about you.

Personal Data Sales and Targeted Advertising Opt-Out

We do not currently sell or process for the purposes of targeted advertising your Personal Data as defined under the MCDPA.

Profiling Opt-Out

We do not process your Personal Data for ‘Profiling’ to make ‘Decisions’ under the MCDPA. ‘Profiling’ means any form of automated processing performed on personal data to evaluate, analyze or predict personal aspects related to an identified or identifiable individual's economic circumstances, health, personal preferences, interests, reliability, behavior, location or movements. ‘Decision’ means any ‘Decisions that produce legal or similarly significant effects concerning a Consumer,’ as defined in the MCDPA that concern you.

Consent or “Opt-in” Required and How to Withdraw

We may seek your consent to collect or process certain Personal Data, including: Sensitive Data, 2) Sensitive Data from a known child under 13 years of age, 3) or to sell, or process Personal Data for Targeted Advertising or Profiling of a consumer age 13 to 15 years old.

If you would like to withdraw your consent, please follow the instructions under the “Exercising Your Rights under State Privacy Laws” section.

We Will Not Discriminate Against You for Exercising Your Rights Under the MCDPA

We will not discriminate against you for exercising your rights under the MCDPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the MCDPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the MCDPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Oregon Resident Rights

If you are an Oregon resident, you have the rights set forth under the Oregon Consumer Privacy Act (“OCPA”). Please see the “Exercising Your Rights under the State Privacy Laws” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are an Oregon resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@openbb.co.

Access

You have the right to request confirmation of whether or not we are processing your Personal Data and to access and request a copy of your Personal Data, including a list of specific third parties, other than natural persons, to which we have disclosed your Personal Data or any Personal Data, in a machine-readable format, to the extent technically feasible, twice within a calendar year.

Correction

Portability

You have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.

Deletion

You have the right to delete Personal Data you have provided to us or we have obtained about you.

Personal Data Sales and Targeted Advertising Opt-Out

We do not currently sell or process for the purposes of targeted advertising your Personal Data as defined under the OCPA.

Profiling Opt-Out

We do not process your Personal Data for ‘Profiling’ to make ‘Decisions’ under the OCPA. ‘Profiling’ means any form of automated processing performed on personal data to evaluate, analyze or predict personal aspects related to an identified or identifiable individual's economic circumstances, health, personal preferences, interests, reliability, behavior, location, or movements. ‘Decision’ means any ‘Decisions that produce legal or similarly significant effects concerning a Consumer,’ as defined in the OCPA that concern you.

Consent or “Opt-in” Required and How to Withdraw

We may seek your consent to collect or process certain Personal Data, including: 1) Sensitive Data, 2) Sensitive Data from a known child under 13 years of age, 3) or to sell, or process Personal Data for Targeted Advertising, or Profiling of a consumer age 13 to 15 years old.

If you would like to withdraw your consent, please follow the instructions under the “Exercising Your Rights under State Privacy Laws” section.

We Will Not Discriminate Against You

We will not discriminate against you for exercising your rights under the OCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the OCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the OCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Texas Resident Rights

If you are a Texas resident, you have the rights set forth under the Texas Data Privacy and Security Act (“TDPSA”). Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Texas resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@openbb.co.

Access

You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.

Correction

Portability

You have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.

Deletion

You have the right to delete Personal Data you have provided to us or we have obtained about you.

Personal Data Sales and Targeted Advertising Opt-Out

We do not currently sell or process for the purposes of targeted advertising your Personal Data as defined under the TDPSA.

Profiling Opt-Out

We do not process your Personal Data for ‘Profiling’ as defined under the TDPSA. ‘Profiling’ means any form of solely automated processing performed on personal data to evaluate, analyze, or predict personal aspects related to an identified or identifiable individual’s economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

Consent or “Opt-in” Required and How to Withdraw

We may seek your consent to collect or process certain Personal Data, including: 1) Sensitive Data, or 2) Sensitive Data from a known child under 13 years of age.

If you would like to withdraw your consent, please follow the instructions under the “Exercising Your Rights under State Privacy Laws” section.

We Will Not Discriminate Against You for Exercising Your Rights Under the TDPSA

We will not discriminate against you for exercising your rights under the TDPSA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the TDPSA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the TDPSA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Utah Resident Rights

If you are a Utah resident, you have the rights set forth under the Utah Consumer Privacy Act (“UCPA”). Please see the “Exercising Your Rights under the State Privacy Laws” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Utah resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@openbb.co.

Access

You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.

Portability

You have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.

Deletion

You have the right to delete Personal Data that you have provided to us.

Opt-Out of Certain Processing Activities

Targeted Advertising: We do not process your Personal Data for targeted advertising purposes. Sale of Personal Data: We do not currently sell your Personal Data as defined under the UCPA. Processing of Sensitive Personal Data: We do not process Sensitive Personal Data. We Will Not Discriminate Against You for Exercising Your Rights Under the UCPA

We will not discriminate against you for exercising your rights under the UCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the UCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the UCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Virginia Resident Rights

If you are a Virginia resident, you have the rights set forth under the Virginia Consumer Data Protection Act (“VCDPA”). Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Virginia resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@openbb.co.

Access

You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.

Correction

Portability

You have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.

Deletion

You have the right to delete Personal Data you have provided to us or we have obtained about you.

Consent or “Opt-in” Required and How to Withdraw

We may seek your consent to collect or process certain Personal Data, including: 1) Sensitive Data, or 2) Sensitive Data from a known child under 13 years of age.

If you would like to withdraw your consent, please follow the instructions under the “Exercising Your Rights under State Privacy Laws” section.

Opt-Out of Certain Processing Activities

Targeted Advertising: We do not process your Personal Data for targeted advertising purposes.
Sale of Personal Data: We do not currently sell your Personal Data as defined under the VCDPA.
Processing for Profiling Purposes: We do not currently process your Personal Data for the purposes of profiling.

To exercise any of your rights for these certain processing activities, please follow the instructions under the “Exercising Your Rights under State Privacy Laws” section.

We Will Not Discriminate Against You for Exercising Your Rights Under the VCDPA

We will not discriminate against you for exercising your rights under the VCDPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the VCDPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the VCDPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Exercising Your Rights under the State Privacy Laws

To exercise the rights described in this Privacy Policy, you or, if you are a California, Colorado, Connecticut, Montana, Oregon, or Texas resident, your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

Request to Opt-Out of Sale, Share, and/or Targeted Advertising

You may opt-out from any “sales,” “shares,” or targeted advertising, by using the following methods:

Email us at support@openbb.co
By implementing the Global Privacy Control or similar universal privacy control that is legally recognized by a government agency or industry standard and that complies with applicable State Privacy Laws. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal. Please note this does not include Do Not Track signals.

Request to Opt-Out of Profiling

If you are a Colorado, Connecticut, Montana, Oregon, Texas, or Virginia resident, you may opt-out of Profiling for Decisions. You can opt-out using the following methods:

Email us at support@openbb.co

Request to Opt-Out of Processing of Sensitive Personal Data

If you are a Utah resident, you may opt-out of processing of your Sensitive Personal Data. You can opt-out using the following methods:

Email us at support@openbb.co

Request to Limit the Use of Sensitive Personal Information

If you are a California resident, you may exercise your Right to Limit by using the following methods:

Email us at support@openbb.co

Request to Withdraw Consent to Certain Processing Activities

If you are a Colorado resident, you may withdraw your consent allowing us: 1) to process your Sensitive Data (including Sensitive Data Inferences), 2) to process your Personal Data if you are a known child under 13 years of age, 3) to sell, or process your Personal Data for Targeted Advertising or Profiling after you have exercised your right to opt-out, or 4) to process your Personal Data for Secondary Use, by using the following methods:

Email us at support@openbb.co

If you are a Connecticut resident, you may withdraw your consent allowing us: 1) to process Sensitive Data, 2) to process Sensitive Data if you are a known child under 13 years of age, or 3) to sell, or process Personal Data for Targeted Advertising if you are at least 13 years old but younger than 16 years old, by using the following methods:

Email us at support@openbb.co

If you are a Montana or Oregon resident, you may withdraw your consent allowing us: 1) to process Sensitive Data, 2) to process Sensitive Data if you are a known child under 13 years of age, or 3) to sell, or process Personal Data for Targeted Advertising or Profiling of a consumer age 13 to 15 years old by using the following methods:

Email us at support@openbb.co

If you are a Texas or Virginia resident, you may withdraw your consent allowing us: 1) to process Sensitive Data, or 2) to process Sensitive Data if you are a known child under 13 years of age, by using the following methods:

Email us at support@openbb.co

Request to Access, Delete, or Correct

You may submit a Valid Request for any other rights afforded to you in this Privacy Policy by using the following methods:

Email us at: support@openbb.co

If you are a California, Colorado, Connecticut, Montana, Oregon, or Texas resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf. Appealing a Denial

If you are a Colorado, Connecticut, Montana, Oregon, Texas, or Virginia resident and we refuse to take action on your request within a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision. In such an appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the State Privacy Laws (as applicable). We will respond to your appeal within the time period required under the applicable law. You can submit a Verified Request to appeal by the following methods:

Email us at: support@openbb.co (title must include “[STATE OF RESIDENCE] Appeal”)

If we deny your appeal, you have the right to contact the Attorney General of your State, including by the following links: Colorado, Connecticut, Montana, Oregon, Texas, and Virginia.

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes. To submit such a request, please contact us at support@openbb.co.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites, web applications, and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To learn more about “Do Not Track,” visit www.allaboutdnt.com.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at support@openbb.co with the subject line “Nevada Do Not Sell Request” and providing your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, or your choices and rights regarding such collection and use, please contact us at:

Website: https://www.openbb.co/
Email: support@openbb.co
Address: 7726 Gunston Plz, P.O Box 194, Lorotn VA 22199