Origin Privacy Policy

Updated: April 16, 2020
INTRODUCTION Origin Financial’s (“Origin”) priority is your trust. Your privacy is essential to earning and keeping that trust. This drives all of the decisions we make, as well as how we gather, use and store any information we acquire from you. We created this Privacy Policy to be as clear and direct as possible about how we gather and use your nonpublic personal information and other types of personal information (“Personal Information”).

HOW YOU ACCEPT THIS POLICY By using and continuing to use the Origin Websites (“Site”), Services, or otherwise providing us with personal information (such as an email address) you agree to the terms and conditions of this Privacy Policy and any updates thereto. This policy may change from time to time. This is our entire and exclusive Privacy Policy and it supersedes any earlier version. These terms and conditions take precedence over any conflicting Privacy Policy provision.

INFORMATION COLLECTION In order to provide a high-quality service, Origin collects various types of information when you visit the site, sign-up as a Client, or otherwise engage with Origin. This Privacy Policy describes how Origin treats your Personal Information when you use or evaluate our Site and/or Service or when you apply to and/or become an employee (“Employee”). For the purpose of this Privacy Policy, a User is an individual who uses our Site to understand or evaluate our Service; and a Client is an individual who signs our Client Agreement that entitles the Client to have their investment portfolio evaluated by Origin. The type of information we collect depends on whether you are a current or former User, Client and/or Employee. We collect Personal Information from you when you voluntarily provide it to us. Examples of instances when we collect Personal Information include:
●  when you answer questions on the Site to determine what kind of portfolio we might recommend if you were to become a Client,
●  when you register to open an account,
●  when you contact our client service organization with questions,
●  when you become a Client, or
●  when you apply to become or become an Employee.
Wherever Origin collects Personal Information, we endeavor to provide a link to this Privacy Policy.

User/Visitor Information We collect Personal Information such as name, address, telephone number and other information you may provide, such as your age, investable assets, and risk tolerance, which may include your financial goals and objectives, income information and other financial planning information about your household. We may collect your email address and/or telephone number should you engage with us via our Site, or email or by calling our client service team. We collect various types of anonymous information about visitors to Origin, such as device-related information (including browser type and IP address) and server log information (including the date and time of day of your visit, average time spent on the Origin site, browsing activity, and any site that referred you to Origin). We also collect information that you input into our website, e.g., by beginning the account application process. We use this information to better understand our visitors and our business, facilitate site navigation, provide the services or information you request, and enhance the Origin service. Client/Customer Information If you choose to become a Client, in addition to the information we collect from you as a User, described above, we will ask you for certain additional Personal Information, including but not limited to: ●  your and your beneficiaries’ full legal name, contact information, birth date, Social Security Number, citizenship;
●  your investment objectives, approximate net worth, and other regulatory disclosures that may be necessary and required by federal and certain statutory laws (see our Client Agreement);
●  account numbers and login credentials for the accounts (bank or brokerage) you choose to link to our Service, any challenge and/or security questions associated with those accounts and any information contained in those accounts.
●  Note: if you choose to link to our Service, we may use a third-party service to aggregate your account data.
If you use Zoom to initiate a screen share with Origin’s customer support team, you acknowledge and agree that Zoom may collect certain information about your location, as well as the timing and your use of its services, in accordance with its Privacy Policy (located at https://zoom.us/privacy).


Information Collected as Authorized Agent
Many of Origin’s Clients choose to aggregate information from accounts at other financial institutions onto their dashboard on our Site; in enabling this functionality, Origin acts as an agent to retrieve the Client account information maintained by such third-party financial institutions with which the Client has a legally-binding customer relationship (“Account
Information”). This Account Information may include account balances, transactions and holdings from the linked financial institutions. By choosing to use our Service to aggregate and analyze Account Information, you expressly authorize and direct Origin, on your behalf, to electronically retrieve Account Information. Origin may work with one or more third-party financial service providers to access and retrieve your Account Information. Employee Information To ensure proper compliance and oversight Origin retains certain relevant information about our Advisers, Supervised Persons and employee personnel as per Origin’s Code of Ethics, which is based on published guidance by the SEC.

Information Regarding Children
Due to the nature of our business, Services and benefits are not marketed to minors. Except for beneficiary information as described above, Origin does not knowingly solicit Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information to Origin. If we learn that we have collected Personal Information directly from a minor, we will delete such information from our files. If a parent or guardian becomes aware that his or her child under the age of 18 has directly provided us with Personal Information without his or her consent, he or she should contact us at info@useorigin.com and we will delete such information from our files.

Other Ways We Collect Information
Other means by which we collect Personal Information include the following:
●  Anonymized or aggregated Information. Origin’s Site automatically records certain anonymized or aggregated information about your use or evaluation of our Service. Anonymized or aggregated information is used for a variety of functions, including the measurement of Users’ interest in and use of various portions or features of the Site. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including internal analysis, analytics and research. We may share this information with third parties for our purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
●  Pixel Tags. We may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow us to monitor the use of our Sites. A pixel tag can collect information such as the Internet Protocol (“IP”) address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server.
●  “Do Not Track” Technology. We do not collect Personal Information about your online activities over time and across different websites or online services. Therefore, our Site
does not respond to Do Not Track (“DNT”) signals. We do not knowingly authorize third-parties to collect Personal Information about your online activities over time and across different websites or online services. Cookies and Pixels Cookies are small pieces of data that are stored on your computer, mobile phone or any other device used to access the internet. Pixels are small code blocks on a website that allow for another server to measure viewing of a webpage and often are used in connection with cookies. We use these technologies to customize Origin and improve your experience with the site. Cookies store anonymous information, such as whether you viewed the site from your mobile device. We may store some personal information in a cookie and/or pixel, such as the site that you visited immediately prior to visiting Origin and relevant financial information that allows us to enhance your user experience and for marketing purposes. Additionally, we may use a cookie and/or pixel that only stores anonymous information to track visitors across websites or devices to better customize our marketing and advertising campaigns. Cookies do not store any of the Personal Information that you have provided to us; they are simply identifiers. You may delete cookie files from your own hard drive at any time. Cookies, pixels, and similar technologies are not required for site functionality. You are not required to accept any cookies or pixels to use this site. However, refusing to accept cookies or pixels will make the use of Origin more cumbersome and less accessible. Analytics Services We use third-party analytics tools, including “Google Analytics” (such tools collectively referred to as “Analytics Services”) to collect information about the usage of the Site. The Analytics Services collect information about how often users visit the Site, what pages they visit when they do so, and what other sites they used prior to coming to the Site, among other information. We use the information we get from these Analytics Services to improve the Site. These Analytics Services collect the IP address assigned to you on the date you visit the Site, along with other anonymized information (e.g., browser type and type of device used to visit the Site), but not your name or other personally identifiable information. The Analytics Services’ ability to use and share information about your visits to the Site is restricted by their terms of use and privacy policies. We do not combine the information collected through the use of Google Analytics with personally identifiable information. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser. You can opt-out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on here. Advertising We do not allow third-party advertising on our Site.

INFORMATION USE

Use of Personal Information
We use your Personal Information to help you evaluate our Service, offer you new products or services, and enhance our Service. We may also use your personal information a number of ways, including research, internal analysis, and analytics.

Use of Client Personal Information
Origin stores, processes, and maintains Personal Information related to you in order to provide client support, offer new products or services and provide our Service to Clients in accordance with the rules of regulatory bodies such as the Securities and Exchange Commission (the “SEC”) and Financial Industry Regulatory Authority, Inc. (“FINRA”). As a User, you may choose not to provide such information to us, but if you choose not to provide such information, you will not be able to become a Client. Additionally, we may share the information required to become a Client with our brokerage partner(s) solely to allow our brokerage partner(s) to provide services to you. If a Client is also a User, the provisions hereunder related to Users will apply to such Personal Information in those circumstances.

Mobile Computing
Origin provides websites and online resources that are specifically designed to be compatible for use with mobile computing devices. Mobile versions of our website are governed by the provisions hereunder related to the Site and may require that you log in with an account. In such cases, information about the use of each mobile version of the website may be associated with your accounts. In addition, we may enable individuals to download tools, such as an application, widget or other tool, that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to Origin to enable you to access your account information and to enable us to track the use of these tools. Some of these tools may enable users to email reports and other information from the tool. We may use Personal Information or non-identifiable information transmitted to us to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices we provide.

Information Sharing and Onward Transfer
We will not sell, rent, or trade your Personal Information (whether you are a current or former User, Client and/or Employee) to any nonaffiliated third-parties except as required by law, such as when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, front running or scalping, situations involving potential threats to the physical safety of any person, or violations of our Terms of Use. Origin may share your Personal Information among affiliated Origin entities in connection with the provision of Services to Clients and Users. There are certain circumstances in which we may share your Personal Information with nonaffiliated third-parties without further disclosure to you. For example, from time-to-time, we hire third-parties to perform certain business and technology related functions (e.g., mailing information, database maintenance and payment processing). In the case we hire a third party to perform a function of this kind, we endeavor to only provide them with the minimum information they need to perform their specific function and to require these third parties to safeguard your information. If you conduct business with us through Origin, we may exchange information we collect with your investment professional or with others they may authorize. In order to provide workplace services to employers or plan sponsors, such as retirement savings plan services and recordkeeping services, we may exchange any information received in connection with such services with the employer or plan sponsor or others they may authorize. We may also share information, including but not limited to account positions, contributions, distributions, and cash flows, with a third-party financial institution that serves as a directed trustee to 401(k) plans serviced by Origin for business and its affiliates. We will never rent, sell or trade your Personal Information to anyone. Ever.

YOUR CHOICES AND OPTING OUT
You have the right to opt out of certain uses and disclosures of your Personal Information, as set out in this Privacy Policy. You may decline to provide Personal Information to Origin. Declining to provide personal information may disqualify you from using Origin Services, Site, and features that require certain Personal Information.

Opting-Out - Obtaining and Withdrawing Consent
Where you have consented to Origin’s use of your Personal Information, you may withdraw that consent at any time and opt out by contacting us by email, phone or physical mail via the contacts indicated under the “Questions and Contacting Us” section below. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out. Prior to disclosing sensitive Personal Information to a third-party or processing sensitive Personal Information for a purpose other than its original purpose, the purposes set forth under this Privacy Policy or the purpose authorized subsequently by you, we will endeavor to obtain your explicit consent (opt-in). Where your consent for the processing of Personal Information is otherwise required by law or contract, we will comply with the law or contract. We will use Employee Personal Information only for employment-related purposes. If we intend to use this Employee Personal Information for any other purpose, we will provide the Employee with an opportunity to opt-out of such use.

Restricting Communications Origin may use your Personal Information to communicate with you regarding our Service or to tell you about blog posts or Services that we believe will be of interest to you. If you decide at any time that you no longer wish to receive communications from us, please follow the “unsubscribe” instructions provided in the communications or contact us at info@useorigin.com. Please note that you cannot opt-out of administrative communications such as regulatory, billing or service notifications.

ACCESSING YOUR PERSONAL INFORMATION
Users or Clients may contact us at info@useorigin.com to request information about how to access your Personal Information.
●  Origin provides all Clients with continuous access via the Site to prompt reporting information about account status and balances.
●  Clients can access or amend their Personal Information at any time by signing in to your Origin account via our Site.
●  Your requests will be processed in line with local laws, including without undue delay and in accordance with any required time frames.

Although Origin makes good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will endeavor to provide you with an explanation of why that determination has been made within one month of the request, a contact point for any further inquiries and any other legally required information. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access or making any changes to your Personal Information.

Retention and Deletion

Origin retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Site or Services or as necessary to fulfill the purpose(s) for which it was collected, to provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, or as otherwise required to comply with contracts and comply with all applicable laws.

You may request deletion of Personal Information by contacting us at info@useorigin.com and providing us enough information to identify your account and prove that you are the owner of the identified account. However, we may retain residual information related to your account, as well as any data related to your trades, in accordance with applicable laws. In no case will we share any individual trading data unless required by regulators or other government bodies, or in accordance with applicable laws.

SECURITY Origin takes reasonable steps, endeavoring to use appropriate technical or organizational measures, to protect your Personal Information from loss, misuse, and unauthorized access, alteration, disclosure, or destruction. However, no Internet, email, or electronic operating system that enables the transmission of data is ever fully secure or error free therefore, we cannot ensure or warrant the security of any information you transmit to us. Origin works diligently to protect your personal information. We employ several physical and electronic safeguards to keep your information safe. We use the strongest available browser encryption, store all of our data on servers in secure facilities, and implement systematic processes and procedures for securing and storing data. We limit access to your personal and financial information to only those employees with authorized access who need to know the information in order to perform their jobs, and we require third parties who perform services for Origin to agree to keep your information confidential. Furthermore, if you choose to close your account or your account is terminated with us, we will continue to adhere to the privacy policies and practices outlined here. If you maintain an Origin account that you access through our Site, you are responsible for protecting and maintaining the confidentiality of your account and password and restricting access to your computer.

OTHER IMPORTANT INFORMATION Changes to the Policy We may modify this Privacy Policy over time without prior notice by posting a new version of this Privacy Policy, which is your responsibility to review. Any changes to the Privacy Policy will be reflected on this page and will become effective immediately upon posting. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the personally identifiable information we collect. If changes to the Privacy Policy are material, we will do our best to notify you via email or through a notification on the site or app. Please check the effective date below to determine if there have been any changes since you have last reviewed the Origin Privacy Policy.

Former Customers If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current customers.

Social Media and Links to Other Web Sites and Applications: “Linked Third-Party”
This Privacy Policy and these terms apply only to Origin operated services and applications. Please note that our Sites may contain links to other websites, applications, social media accounts, and information for your convenience that are not operated or controlled by Origin. Origin does not control Linked Third-Party websites or their privacy practices, which may differ from those set out in this Privacy Policy. Origin does not endorse or make any representations about Linked Third-Party information. Any Personal Information you choose to give to Linked Third-Parties is not covered by this Privacy Policy. We encourage you to review the Privacy Policy of any company or website before submitting your Personal Information. Some third- parties may choose to share their users’ Personal Information with us; that sharing is governed by that company’s Privacy Policy, not this Privacy Policy.

California Privacy Rights
California law permits Users and Clients who are California residents to request and obtain from us once a year, free of charge, a list of the third-parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Origin does not share Personal Information with third-parties for their own marketing purposes.

QUESTIONS AND CONTACTING US
If after reviewing this Privacy Policy, you would like to submit a request, opt-out or you have any questions or privacy concerns, please contact us by email at info@useorigin.com.