Path strives to protect your privacy and secure your non-public personal information. This policy is intended to communicate to you the ways in which Origin Investments, Origin Holding Company, LLC and Path by Origin, LLC (collectively, “Origin”) gather, use and store any information we acquire from you, including through Origin’s websites (www.origininvestments.com and www.pathbyorigin.com) and our mobile applications for IOS and Android devices (such applications and websites, collectively, the “Platform”).
How We Collect Information
We collect various types of anonymous information about visitors (“Users”) to our Platform, 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 an Origin site, browsing activity, and any site that referred you to Origin). We also collect information that Users input into our websites. 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 Platform experience.
If you create an account on our Platform, we will also collect certain personal information, which may include your full legal name, email address, permanent address, date of birth, social security number and information about your investible assets and risk tolerance, which may include your financial goals and objectives, income information and other financial planning information about your household. In some instances (e.g., for advisory services) we are required by law to collect this information in order to provide you with the services you are requesting. In those instances, if you do not wish to provide this information, you cannot become a client of Origin.
Cookies and Pixels
Along with cookies, we may use “pixel tags,” which are small graphic files that allow us to monitor the use of our Platform. A pixel tag can collect information such as the 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.
Origin may also use third-party tracking technology, such as Google Analytics, to record similar information regarding User activity on our Platform.
How We Use Your Information
We use your Personal Information to help you evaluate Origin and our products and services, to offer you new products or services, and to enhance our interaction with you. We may also use your personal information a number of ways, including research, internal analysis, and analytics.
We may also use your personal information to contact you regarding Origin information, products and services that we think may be of interest to you. If you no longer wish to receive such communications via email from Origin, please click the “unsubscribe” link found at the bottom of each email message; however, if you are a Client of Origin, there are certain communications related to the administration of your account that are required to be delivered, regardless of whether you are “unsubscribed.”
We do not sell, rent, or trade your personal information with any third parties other than with your consent or as required by law.
In order to provide financial services and in connection with our everyday business purposes and activities, we may share your personal information with third parties who perform services on our behalf.
Examples of these third parties and services include consumer identification verification services, public accounting firms and other professional firms, and certain other vendors and service providers who perform administrative, custodial, marketing, advertising, research and analytics services on our behalf. We have entered into agreements that require that these third parties keep this information confidential.
How We Protect Information
Origin places your account information in a protected and secure portion of our Platform and employs firewalls and security technology to protect our network and systems from external attacks. We limit access to your personal information to 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. As a Client, you are required to utilize a unique user name and password to access your account information online, and we use SSL (Secure Socket Layer) technology to protect the security of the information transmitted between your computer and our servers.
While Origin endeavors to use appropriate technical and organizational measures to protect your personal information from loss, misuse, unauthorized access, alteration, disclosure and destruction, no Internet, email, or electronic operating system that enables the transmission of data is ever fully secure or error free; accordingly, we cannot ensure or warrant the security of any information you transmit to us.
Specific User Information
Residents of California have the right to request from us certain information with respect to the types of personal information we share with third parties for those third parties’ direct marketing purposes and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year.
To exercise your rights, you may make one request each year by emailing us at email@example.com. Your request should specify your full name and the email address you used when submitting personal information to us.
We do not share nonpublic personal financial information we collect about Vermont residents to non-affiliated third parties except for our everyday business purposes or as otherwise permitted by law. If you wish to revoke any authorization to share your nonpublic personal financial information, which you have provided to us by entering into an Advisory Agreement, please contact us at firstname.lastname@example.org. Please note, however, that we will not be able to provide you with services through our Platform without the ability to share this financial information.
None of Origin’s products, services or Platform are directed towards anyone under the age of 18. If we become aware at any point that a child under the age of 18 has created an account, we will terminate his or her account.
Acceptance and Changes
Dated: January 10, 2020