Last updated: December 2022
1. What Personal Information We Collect
The personal information we collect from or about you may include the following:
- Addresses and other identifiers – such as name, postal address, email address, phone number, account name, date of birth, Social Security number, driver’s license number, photograph, passport number, or other similar identifiers
- Protected status – such as citizenship, ethnic background, gender or other similar identifiers
- Internet or other electronic network activity – such as browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement
- Financial information – such as bank account details, credit history, income details or other similar identifiers
- Commercial information – such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies or other similar identifiers
- Education or other professional information, including veteran status or other similar information
- Audio or video footage collected using CCTV cameras (only if you visit one of our premises that uses this technology)
- Biometric information – specifically, fingerprints.
- Geolocation information
- Inferences drawn from personal information – such as individual profiles, preferences, characteristics, behaviors or other similar identifiers
Whether you choose to provide any particular information requested by OFS is completely your own choice. But, if you choose not to provide the information we request, you may be unable to receive or access certain services, offers and information.
We do not sell or share personal information, as those terms are defined in the California Consumer Privacy Act, as amended (“CCPA”).
2. Purpose for Collection
We may collect your personal information for the following purposes:
- To provide you services, including customer support, processing and fulfilling orders, processing payments, or booking travel arrangements
- To contact you to discuss the services or products you receive from us
- To respond to any questions or concerns you have raised
- To deal with administrative matters such as invoicing, renewal or audit of customer transactions
- To otherwise carry out our obligations arising under our contract with you and to enforce the same
- To comply with legal requirements, including those related to anti-money laundering
- To verify your identity or for other fraud and/or crime prevention purposes
- To monitor safety, fraud, and/or employee theft
- To debug errors in our systems
- For marketing and advertising purposes
- For internal research, analytics and development
- In connection with your application for or employment with us
We keep your personal information for as long as it is required by us for our legitimate business purposes, to perform our contractual obligations, in connection with your application for or employment with us, in connection with any investment you are involved in, and in accordance with our data retention schedule. We may retain your personal information for a longer period if doing so is necessary to comply with our legal or reporting obligations, or as otherwise permitted or required by law. We may also retain your personal information in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your personal information, we consider various factors, such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your personal information; and applicable legal requirements.
5. Collecting the Personal Information of Minors
Our products and services are not directed to minors under the age of 16 and we do not knowingly collect or sell the personal information of minors.
6. Your Choices Regarding Direct Marketing
On occasion, we may send you email communications about our company and our products. If you change your mind about receiving marketing communications from us and wish not to receive further marketing communications from us, please let us know that you would like to “opt out” by emailing us at firstname.lastname@example.org, contacting us at 1-833-687-3622 or using this webform.
Some email communications from us include instructions on how to stop receiving them. Please follow these instructions if you no longer wish to receive email messages from us.
7. Online Advertising
8. Protecting Your Personal Information
We implement and maintain reasonable data security safeguards appropriate to the nature of the personal information that we collect, use, retain, transfer or otherwise process. Our policy is to restrict access to your personal information to only those employees, service providers and other third parties who need to know that information to provide products or services to you. We maintain commercially reasonable physical, technical, and administrative safeguards consistent with industry standards and other applicable standards as required by law and we require service providers and third parties to do the same.
While we are committed to developing, implementing, maintaining, monitoring and updating a reasonable information security program, unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. Data security incidents and breaches can occur due to vulnerabilities, criminal exploits or other factors that cannot reasonably be prevented. Accordingly, while our reasonable security program is designed to manage data security risks and thus help prevent data security incidents and breaches, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through the website cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.
9. Links to Third-Party Websites
10. Policy Changes
11. Additional Privacy Terms
12. Your Feedback
13. California Privacy Rights and Disclosures
These obligations and rights apply to businesses doing business in California and to California residents and information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with California consumers or households. It does not include deidentified or aggregate information, publicly available information, or lawfully obtained, truthful information that is a matter of public concern.
The following chart describes the categories of personal information we may collect or have collected about you in the past 12 months and, for each category, where and why we collect it, and the categories of entities to whom we disclose the personal information, if any:
|Category of Personal Information (PI)||Sources from which PI is/was collected||Purpose of collection||Categories of entities with whom PI is/was disclosed|
|Address and other identifiers – such as name, postal address, email address, phone number, account name, date of birth, Social Security number, driver’s license number, photograph, passport number, or other similar identifiers
NOTE: The information in this category may include the following elements of Sensitive Personal Information: social security number, driver’s license number, state identification card number, and/or passport number.
|Protected status – such as citizenship, ethnic background, gender or other similar identifiers
NOTE: The information in this category may include the following elements of Sensitive Personal Information: racial, ethnic, or national origin.
|Internet or other electronic network activity – such as browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement
NOTE: The information in this category may include the following elements of Sensitive Personal Information: the contents of mail, email, or text messages, to which the business was not the intended recipient.
|Financial information such as bank account details, credit history, income details or other similar identifiers
NOTE: The information in this category may include the following elements of Sensitive Personal Information: log-in, financial account, debit card, or credit card number, in combination with any required security or access code, password, or credential allowing access to an account.
|Commercial information – such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies or other similar identifiers||
|Education or other professional information, including veteran status or other similar identifiers
NOTE: The information in this category may include the following elements of Sensitive Personal Information: union membership.
|Audio or video footage collected using CCTV cameras (only if you visit one of our premises that uses this technology)||
NOTE: Biometric information is considered an element of Sensitive Personal Information.
NOTE: The information in this category may include the following elements of Sensitive Personal Information: precise geolocation.
|Inferences drawn from CCPA PI – such as individual profiles, preferences, characteristics, behaviors or other similar identifiers||
a. Your Right to Request Disclosure of Information We Collect and Disclose about You
If you are a California resident, the CCPA grants you the right to request certain information about our practices with respect to personal information. In particular, you can request the following:
- The categories of your personal information that we’ve collected.
- The specific pieces of your personal information that we’ve collected.
- The categories of sources from which we collected your personal information.
- The categories of your personal information that we’ve sold or disclosed for a business purpose.
- The business or commercial purposes for which we collected, sold, or shared your personal information.
- The categories of third parties to whom we’ve disclosed your personal information.
To exercise your CCPA right to request this information, either email us at email@example.com, contact us at 1-833-687-3622 or use this webform. These requests for disclosure are generally free.
b. Your Right to Request the Deletion of Personal Information
Upon your request, and subject to certain exceptions, we will delete, and direct applicable service providers to delete, the personal information we have collected about you.
To exercise your right to request the deletion of your personal information, either email us at firstname.lastname@example.org, contact us at 1-833-687-3621 or use this webform. These requests for deletion are generally free.
c. Your Right to Ask Us Not to Sell or Share Your Personal Information
We do not, and will not, sell or share your personal information.
d. Your Right to Request the Correction of Your Personal Information
Upon your request, and subject to certain limitations, we will correct any inaccurate personal information we maintain about you.
To exercise your right to request the correction of your personal information, either email us at email@example.com, contact us at 1-833-687-3621 or use this webform. These requests for correction are generally free.
e. Our Use or Disclosure of Sensitive Personal Information
We only use and disclose Sensitive Personal Information for the purposes set forth in Section 7027(m) of the CCPA regulations.
f. Our Support for the Exercise of Your Data Rights
g. How We Will Handle a Request to Exercise Your Rights
For requests for access or deletion, we will first acknowledge receipt of your request. We will provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances. If we expect your request is going to take us longer than normal to fulfil, we’ll let you know.
When you make a request to access, correct, or delete your personal information, we will take steps to verify your identity. These steps may include asking you for personal information, such as your name, address, or other information we maintain about you. If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.
You may also designate an authorized agent to submit requests on your behalf. If you do so, you will be required to verify your identity by providing us with certain personal information as described above. Additionally, we will also require that you provide the agent with written permission to act on your behalf, and we will deny the request if the agent is unable to submit proof to us that you have authorized them to act on your behalf.
14. European Privacy Rights and Disclosures
This European Privacy Rights and Disclosure section addresses legal obligations and rights specified in the General Data Protection Regulation, or GDPR. These obligations and rights apply to individuals who are located in the European Economic Area. This section describes the policies and procedures followed by OFS regarding the collection, use and disclosure of your personal data when you visit the website, or otherwise interact with OFS. For the purposes of this section (European Privacy Rights and Disclosures), personal data means any information relating to an identified or identifiable natural person, either directly or indirectly.
According to the GDPR, OFS is the controller of your personal data.
a. Collection of Your Personal Data
When you visit the website, receive services from us or otherwise interact with us, we may collect the following personal data about you: your name, postal address, email address, phone number, account name, date of birth, Social Security number, driver’s license number, photograph, passport number, employer, job title, bank account information, financial information such as your income and net worth, risk tolerance and transaction history, details about your investment activity or retirement portfolios and information about your transactions with us such as the investment amount and any contributions and/or distributions, as well as any other information you choose to provide to us.
Where OFS carries out background checks on certain individuals for a business purpose, this may involve the processing of data relating to criminal convictions and offences. This data will only be processed where such processing is specifically required or authorized by law.
b. Use of Your Personal Data
We may use the personal data you give us to carry out the following purposes:
|To contact you and to respond to your requests and enquiries when you contact us, or subscribe to receive email alerts||We have a legitimate interest to respond to your requests and enquiries for ongoing business administration|
|To deliver services to you||To manage and perform our contract with you|
|For recruitment purposes||We have a legitimate interest to consider an applicant for a role or vacancy in accordance with our recruitment process|
|To send you our newsletter/bulletin or any other direct marketing information||Where we have received your consent|
|For business administration, including statistical analysis||We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are effective and efficient|
|To personalise your visit to the website and to assist you while you use the websites||We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are effective and efficient|
|To improve the website by helping us understand who uses the websites||We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are effective and efficient|
|For fraud prevention and detection and to comply with applicable laws, regulations or codes of practice||To comply with our legal obligations|
You have the right to object to processing of your personal data where that processing is carried out for our legitimate interest.
c. Sharing Your Personal Data
In some cases, we may be required to disclose certain personal information to comply with legal or regulatory obligations; to comply with the charter of the applicable entity into which you invest; to detect and protect against fraud, or any technical or security vulnerabilities; for an investigation or a legal process, such as a court order or subpoena; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to the website, our businesses, or the public. In addition, OFS may disclose certain personal information to any third party that acquires, or is interested in acquiring, all or part of OFS’s assets or shares, or that succeeds OFS in carrying on all or a part of its business, whether by merger, acquisition, reorganization or otherwise.
d. International Transfers
e. Rights of Individuals
You may have certain data privacy rights which may be subject to limitations and/or restrictions. These rights include the right to: (i) request access to and rectification and erasure of your personal data; (ii) obtain restriction of processing or to object to processing of your personal data; and (iii) ask for a copy of your personal data to be provided to you, or a third party, in a digital format. You also have the right to lodge a complaint about the processing of your personal data with your local data protection authority. If you would like to exercise any of these rights, please feel free to email us at: firstname.lastname@example.org.