Privacy Policy

Privacy Policy

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

User 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.

Client Information

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.

If you use the Plaid service to link a bank account when signing up for, or otherwise utilizing, an Origin account, Origin will collect information about the cash flows into and out of that bank account. You acknowledge and agree that the information you provide to Origin through Plaid will be treated by Plaid in accordance with its privacy policies (located at https://plaid.com/legal/#privacy-policy), and by Origin according to this privacy policy.

Cookies and Pixels

Similar to other technology platforms and services, Origin uses cookies, which are small data files, to enable our Web servers to “identify” Users each time a User initiates a session on our Site. A cookie is set in order to identify you and tailor the Platform to you. Cookies do not store any of the personal information that you provided to us; they are simply identifiers. You can set many browsers to notify you when a cookie is being placed on your computer and also erase cookies that may have been knowingly or unknowingly set on your computer. You may delete cookie files from your own hard drive at any time; however, cookies may be necessary to provide access to much of the content and many of the features of the Platform.

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.

We may also disclose personal information in response to service of legal process, such as a court order, summons, or subpoena, or as permitted or required by law when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud (including identity theft), frontrunning or scalping, situations involving potential threats to the physical safety of any person, or suspected violations of our Terms of Use.

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

California Residents

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 support@pathbyorigin.com. Your request should specify your full name and the email address you used when submitting personal information to us.

Vermont Residents

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 support@pathbyorigin.com. 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.

International Users

Origin provides its products and services, and its Platform is hosted, solely within the United States. If you are an international User, you should be aware that by providing your personal information, you are permitting the transfer of your personal information to the United States, which may not have the same data protection laws as the country in which you reside, and that you are permitting the use of your personal information in accordance with this Privacy Policy.

Children

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

By using and continuing to use the Origin Platform, 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.

We may update this Privacy Policy from time to time as we deem necessary at our sole discretion 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. Origin encourages you to periodically review this Privacy Policy to stay informed about how we are using and protecting the personal 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.

This is our entire and exclusive Privacy Policy and it supersedes any earlier version. Our Terms of Use take precedence over any conflicting Privacy Policy provision.

Dated: January 10, 2020

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