● 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.
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.
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 firstname.lastname@example.org 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
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.
Information Sharing and Onward Transfer
YOUR CHOICES AND OPTING OUT
Opting-Out - Obtaining and Withdrawing Consent
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 email@example.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 firstname.lastname@example.org 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
You may request deletion of Personal Information by contacting us at email@example.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.
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”
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