Privacy Policy

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Privacy Policy

Open-i Advisors, Inc., DBA, Open Eye Privacy Policy
Effective 2/6/2024

Scope:
Open Eye has developed the following privacy policy to protect individually identifiable information. This policy covers Open Eye and applies to all individually identifiable information that Open Eye obtains when a client engages Open Eye, including both for custom consulting and the report services. Open Eye protects individually identifiable information as follows:

Disclosure:
Open Eye will not sell, trade or disclose to third parties any individually (either client or Open Eye employee) identifiable information, derived from the any Open Eye 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 Eye uses other agents, contractors or companies to perform services on its behalf, Open Eye will ensure that the company protects the individually identifiable information consistent with this policy.

Security:
Open Eye 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 Eye services except as required to operate the service or as otherwise authorized by law.

Improper Conduct:
Open Eye 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 Eye 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 Eye 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 Eye 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 Eye Inc. does not collect personal information directly from individuals in the EU. Personal information may exist in information that is provided to Open Eye 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 Eye 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 in question is publicly available.
The disclosure is reasonably necessary for the establishment or defense of legal claims.
Data Security:
Open Eye Inc. takes data security seriously and has put in place appropriate physical, and electronic procedures to safeguard and secure the information we process.

Data Integrity:
Open Eye Inc. will use personal information only in ways that are compatible with the purposes for which it was collected.

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

Enforcement:
Open Eye Inc. utilizes the self-assessment approach to assure its compliance with our privacy statement. Open Eye 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 Eye will keep this policy current and will inform you of any changes that we make.