PRIVACY POLICY

Last updated May 25, 2018 We Respect Your Privacy This Privacy Policy describes how we may process your personal data when you visit our website at opendoorllc.com (the “Website”). Other or additional privacy policies or statements may apply when you use or access our other websites or other sections of or pages on this Website, or when you purchase, subscribe or participate in our products or services. In the event of a conflict or inconsistency between this Privacy Policy and those other privacy policies or statements, those other privacy policies or statements will prevail to the extent of that conflict or inconsistency in relation to your use of or access to the other websites or other sections of or pages on this Website, or your purchase, subscription or participation in the relevant products or services, as applicable. Please read this Privacy Policy carefully to understand how we process your personal data. If you do not agree with the practices and procedures described in this Privacy Policy, please discontinue using the Website. In the course of serving you as an individual or as someone associated with a corporation or institution, OpenDoor Securities LLC (“we”, “our”, “us” or “OpenDoor”) may collect, hold, use and disclose (‘process’) information about individuals which may constitute personal data. We will only use the information that we collect about you lawfully in accordance with the Data Protection Act 1998 (DPA) and the EU General Data Protection Regulation (GDPR). The most common way to provide this information is via a Privacy Policy. The first principle of data protection is that personal data must be processed fairly and lawfully. The DPA says that in order for the processing to be fair, the data controller (the organization in control of processing the data) has to make certain information available to the data subjects (the individuals whom the data relates to), so far as practicable: Who Are We? The controller of the data of this website is OpenDoor Securities LLC, a company registered in New Jersey, United States. The registered office of the Company is Newport Financial Center, 111 Town Square Place, Suite 1500, Jersey City, NJ 07310. The GDPR requires that the information we provide regarding how we capture personal data must be: concise, transparent, intelligible, easily accessible, written in clear and plain language, particularly if addressed to a child and free of charge. In that vein, we will attempt to be as clear, concise and as easily understood as possible about how we collect, use and store your data. What Personal Data Do We Collect? We collect the following types of personal data about you: Voluntarily Provided Personal Data

  • If you contact us via the Website, we will collect the information that you provide when you do so, such as your name, e-mail address, telephone number, firm name, firm type, and any information included in your message to us.

Automatically Collected Personal Data

  • As you navigate through and interact with the Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including, without limitation, details of your visits to the Website (such as traffic data, location data, logs and other communication data and the resources that you access and use on the Website), information about your computer and internet connection (such as your IP address, operating system and browser type) and other information obtained through third-party analytics tools such as Google Analytics.

Of course, you are not required to supply any of the personal data that we may request. However, failure to supply any of the personal data that we may request may result in our being unable to fulfill or respond to your relevant request. To help us ensure that all information we hold about you is accurate, complete and up to date, you should promptly notify us if there are any changes to your personal data. We shall not be responsible for the authenticity of any personal data or any losses arising from any inaccurate or deficient personal data that you supply to us. What Are the Purposes for Which We Use Your Personal Data? We may process your personal data that we have collected as follows:

  • To fulfill the request for which you provided the data and for other reasons related purposes we determine are appropriate. For example, if you have requested information from us, we may process the personal data you provided to respond to you with the information requested.
  • To contact you about other services and products we offer unless you have opted out of receiving such communications.
  • To exercise or defend our legal rights, or to comply with legal and regulatory obligations and requests anywhere in the world.
  • As otherwise permitted under any applicable law or regulation or if you have provided us with prior consent.

When Do We Disclose Personal Data We Collect About You? You should know that:

  • OpenDoor will not sell, rent, and/or trade your personal data without your permission.
  • OpenDoor will not disclose your personal data, except as described in this Privacy Policy or otherwise authorized by you.

Our processing of your personal data, for the purposes specified in this Privacy Policy, may include disclosure of your personal data as described below. These disclosures may involve overseas storage and other overseas transfer, processing and use of your personal data, and disclosure to these third parties, including in or to countries or territories which do not offer the same level of protection of personal data as may be enjoyed within your home country.

  • To our third-party service providers, suppliers, content and other providers or contractors for the processing of that data solely for our benefit in accordance with this Privacy Policy.
  • To third parties to whom we assign or novate our rights or obligations.
  • To a prospective seller or buyer in the event that we sell or buy any business or assets or if all or substantially all of our assets are acquired by a third party, in which case personal data will be one of the transferred assets.
  • To regulatory or enforcement bodies or courts anywhere in the world as required by applicable law or regulations anywhere in the world or at their request.

How Can You Opt-out of Use of Your Personal Data for Marketing Purposes? If you wish to limit our use of your personal data for marketing purposes, as described in this Privacy Policy, you may do so by:

  • Clicking the “Unsubscribe” link at the bottom of any marketing email you receive from us and following the instructions
  • Submitting a written request via email to support@opendoorllc.com, or by mailing correspondence to OpenDoor, Newport Financial Center, 111 Town Square Place, Suite 1500, Jersey City, NJ 07310

If you choose to email or write to us, your request should include your name, e-mail address, address and telephone number to which the opt-out applies. Written opt-out requests should not be sent with any other correspondence. In order to process your request, we require that the request be provided by you directly and not through a third party. Once you have informed us about your privacy preferences, your opt-out preference will remain in effect with respect to this Privacy Policy until you notify us otherwise. Third Party Links and Ads The Website may contain links to other websites operated by third parties whose information practices may be different than ours. Visitors of those other websites should consult the privacy notices made available on those websites, as we have no control over information or data that is submitted to, or collected by, these third parties. Our Website may also contain third-party advertisements or offers that are complementary to your use of our Website or our products or services. If you choose to use these separate products or services, disclose information to the providers or grant them permission to collect personal data about you, then their processing of your data is governed by their privacy policy. You should evaluate their practices before deciding to use their products or services. How do we Protect the Security and Confidentiality of Your Personal Data We Collect About You? OpenDoor employs various physical, technical and procedural safeguards to protect any information that you provide to us from accidental or unauthorized loss, misuse, damage, modification, access or disclosure. Third parties who process your personal data for us also employ physical, technical and procedural safeguards to protect such information against unauthorized access, destruction or loss. Any communication or material you transmit to us via e-mail or otherwise, including without limitation to any data, questions, comments, suggestions or the like, but not including your personal information and any requests, comments or concerns regarding your personal information, will be treated as, non-confidential and non-proprietary. Cookies and Other Technologies A “cookie” is a piece of data stored on a user’s device to help us improve your access to the Website and identify repeat visitors. Cookies can also enable us to track and target the interests of our users to enhance the experience on the Website. Cookies are not linked to any personally identifiable information. We use a number of different cookies on this site. If you do not know what cookies are, or how to control or delete them, then we recommend you visit www.aboutcookies.org for detailed guidance. We have compiled a list below describing the cookies used on this site and what they are used for. FIRST PARTY COOKIES These are cookies which are set by this website directly. Google Analytics: We use Google Analytics to collect information about visitor behavior on this website. Google Analytics stores information about the pages you visit, how long you are on the site, how you found this site and what you click on. This Analytics data is collected via a JavaScript tag in the pages of our site and is not tied to personally identifiable information. We, therefore, do not collect or store your personal information (e.g. your name or address) through the use of cookies, so this information cannot be used to identify who you are. You can find out more about Google’s position on privacy as regards its analytics service at www.google.com/intl/en_uk/analytics/privacyoverview.html WordPress This website runs the WordPress CMS and cookies are used to store basic data on your interactions with WordPress, and whether you have logged into WordPress. A session cookie is used to remember your log-in for you if you are a registered user and are deemed as strictly necessary to the working of the website. If these session cookies are disabled then various functionality on the site will be broken. More information on session cookies and what they are used for please visit www.allaboutcookies.org/cookies/session-cookies-used-for.html THIRD PARTY COOKIES These are cookies set on your computer by external websites whose services are used on this site. Cookies of this type are the sharing buttons across the site allow visitors to share content onto social networks such as Facebook, Instagram, Google+, LinkedIn, YouTube, Vimeo and Twitter. In order to implement these buttons, and connect them to the relevant social networks and external sites, there are scripts from domains outside of this website. You should be aware that these sites are likely to be collecting information about what you are doing all around the internet, including on this website. You should check the respective policies of each of these sites to see how exactly they use your information and to find out how to opt-out or delete such information Cookies are small, usually randomly encoded, text files that help your browser navigate through our websites. The cookie file is generated by the Website when you access it and is accepted and processed by your computer’s browser software. The cookie file is stored in your browser’s folder or subfolder. Cookies and other technologies such as pixel tags and web beacons enable us to compile statistical information about how you use our Website, including, without limitation, information relating to the frequency of visits, IP addresses, the average length of visits, which pages are viewed during a visit, the effectiveness of any advertising on the Website, authentication information, periods of inactivity, time zones, language preferences and other regional information. We and our third-party service providers may use information from cookies and other technologies for the following purposes:

  • To improve the Website content and performance.
  • To estimate our audience size and usage pattern.
  • To recognize you when you return to the Website.
  • To deliver a better and more personalized service by allowing us to customize the Website according to your individual interests.

Information held in cookies and other technologies set by OpenDoor is kept to a minimum and can only be read by OpenDoor, our authorized third-party service providers or by someone who has physical access to your personal computer. Many web browsers allow you to control the use of most cookies through their browser settings. To learn more about cookies, including information on what cookies have been set on your computer and how cookies can be managed and deleted, visit www.allaboutcookies.org. Our Website also uses Google Analytics to track your activity. To opt out of being tracked by Google Analytics visit http://tools.google.com/dlpage/gaoptout Unless you have adjusted your browser setting so that it will reject cookies, our system will issue cookies when you access or use the Website. Other technologies we may use may not be blocked by your browser or other interface settings. By accessing or using the Website you consent to OpenDoor using cookies and other technologies in accordance with this Privacy Policy. In the event you refuse to accept cookies, some areas of the Website may not function properly or may not be accessible. Children We do not knowingly or intentionally collect information from any person under 13 years of age. If you become aware that such information has been provided by a child under 13, please contact us as set out in the “How Can You Contact Us?” section below, and send the details. What Rights Do You Have? If you wish to access a copy of your personal data or you wish to modify any personal data which we hold about you, or you want us to cease processing any of your personal data held by us, subject to applicable law, you can do so by written request via our contact details set out in the “How Can You Contact Us?” section below. In the case of a request for access to personal data, we reserve the right to charge an appropriate fee, if applicable. You may be required to supply a valid means of identification as a security precaution to assist us in preventing the unauthorized disclosure of your personal data. We will process your request within the time provided by applicable law. How Do We Update this Privacy Policy? We may change or update portions of this Privacy Policy to reflect changes in our practices and or applicable law and regulation. Please check this Privacy Policy from time to time so you are aware of any changes or updates to the Privacy Policy, which may be indicated by a change in the “Last Updated” date noted at the beginning of the Privacy Policy. How Can You Contact Us? If you would like to contact us in respect of any aspect of this Privacy Policy, including, without limitation and subject to applicable law, where you wish to access a copy of your personal data or where you wish to raise a complaint or grievance, please contact us at the following address: OpenDoor Securities, LLC Newport Financial Center 111 Town Square Place, Suite 1500 Jersey City, NJ 07310 Changes to this Privacy Policy We may at any time, without notice to you and in its sole discretion, amend this policy from time to time. Please review this policy periodically. Your continued use of our websites after any such amendments signifies your acceptance thereof.