PRIVACY POLICY

Updated: March 23, 2021

Your privacy is important to Optimal Financial Systems, LLC and its affiliated companies (“OFS,” “our,” “us,” or “we”) and we are committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy applies to information we collect through or in connection with our website at https://optimalfinancial.io/ and any other websites we may operate from time to time (collectively, the “Site “). This Privacy Policy is intended to help you understand how we collect your personal information, what types of personal information we collect, how we use your personal information, with whom your personal information may be shared, how we protect and how long we store it, and what choices you have about how that information is used. This Privacy Policy also describes the choices you can make about how we collect and use your personal information.

By accessing and/or using the Site, you agree that your use of the Site and that any dispute over privacy is subject to this Privacy Policy, and you expressly consent to our collection of your information in the manner described in this Privacy Policy. If you do not agree with this Privacy Policy, please discontinue use of the Site. This Privacy Policy may be revised over time as new features are added to the Site or as we incorporate suggestions from our users and customers. Any material changes will be effective immediately. The amended Privacy Policy will always be posted on the Site.

What Types of Personal Information We May Collect About You:

We collect the following types of personal information about you, as further described below:

• Your personally identifiable information, including your name, postal address, phone number(s), and e-mail address(es);
• Information you share with us about your business;
• Usage details, including button clicks and page visits;
• Device and connection information, including details regarding your Internet Protocol (“IP”) address, browser, and operating system; and
• Your navigation through the Site.

How We Collect Your Personal Information:

We collect personal information about you:

• When you submit personal information through contact forms on our Site or via email;
• When you communicate with us by telephone, email, or mail;
• When we perform intake interviews and when you voluntarily provide to us information about your business;
• When your browser sends us information when you visit the Site;
• Through the use of “cookies”, tracking pixels, and similar technologies. “Cookies” are small files that your Web browser places on your computer’s hard drive; and
• When you provide us with comments or suggestions.

How We Use and Process Any Personal Information That We Collect:

We process and use your personal information primarily to market services that we or our affiliates provide, provide, maintain, and improve the Site, and for marketing efforts. We may use your personal information in the following ways:

• To market and offer our services and services provided by our affiliates that we believe may be of interest to you;
• To better understand how the Site is navigated;
• To improve the Site content;
• To send periodic emails or other communications to you and otherwise conduct internal marketing campaigns;
• To verify activity, to monitor suspicious or fraudulent activity, and to identify violations of our policies;
• To make disclosures under the requirements of any applicable law, such as tax reporting, and to comply with legal process or in response to lawful requests from public authorities;
• To enforce any of our rights under the Terms and Conditions of Use of Website, this Privacy Policy, and any other rights we may have;
• When we have your specific or, where necessary, explicit consent to do so;
• We may also process your personal information for compliance with our legal obligations, including to satisfy laws; and
• To manage and respond to your requests to us.

With Whom We May Share Personal Information We Collect:

We may share your personal information in the following situations:

• With our employees and other service providers, if necessary for the development, improvement, and provision of the Site and/or our service offerings;
• With our affiliates for the purpose of delivering product and service offers and communication to you;
• As required to comply with our legal and regulatory obligations;
• As required to protect the security of the Site and our rights under our Terms and Conditions of Use of Website;
• If we have received your advance permission to do so;
• As required to protect ourselves against liability;
• In response to legal process;
• As required in connection with a sale of our business or company; and
• In addition, we may disclose information that is not in personally identifiable form for any purpose.

How We Keep Secure Any Personal Information We Collect:

We are committed to safeguarding your information. The Site has security measures in place to protect the loss, misuse, and alteration of the personal information under our control. While we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining personal information. All personal information is accessed by us and our service providers on a “need to know” basis only. Additionally, we regularly audit the security of the Site.

How Long We Retain Your Personal information:

To the extent permitted by applicable law, we will retain your personal information until you request that we delete it or otherwise for as long as permitted or required for legal and regulatory purposes. Aggregate information, which is not personal information, is retained indefinitely to improve the functionality of the Site.

Your Personal Information Protection Rights and Choices:

You have the following rights in relation to our processing of your personal information. Please note that these rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

You have the right to:

• To obtain access to, and copies of, the personal information that we hold about you;
• To require us to correct the personal information we hold about you if it is incorrect;
• To require us to delete or restrict your personal information in certain circumstances (e.g., if OFS is using your personal information on the basis of your consent and has no other legal basis to use such, you may request your personal information be deleted when you withdraw your consent);
• To require us to restrict our data processing activities in certain circumstances;
• Select whether we share your personal information with third parties by or change your selection by emailing us at support@optimalfinancial.io and placing “share” or “do-not-share” in the subject line (please include your full name);
• To object to any of our particular processing activities of your personal information;
• To receive from us the personal information we hold about you, in a reasonable format specified by you, including for the purpose of you transmitting that personal information to another data controller;
• Where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal;
• If you are not satisfied with how we are processing your personal information, you can make a complaint to a data protection supervisory authority in the US or EU, as applicable, including the data protection regulator in the EU country where you are located; and
• To request that we restrict the processing of your personal information pending our investigation and/or verification of your claim, if you believe your personal information is inaccurate, no longer necessary for our business purposes, or if you object to our processing of your personal information.

If you want to exercise any of the rights described above or submit a complaint on how we have handled your personal information, please contact us by email at support@optimalfinancial.io.

You also have choices regarding the collection, use, and sharing of your personal information:

• You may opt-out of receiving emails or newsletters and other offers by clicking on the unsubscribe link at the bottom of any of our emails or newsletters; and
• You may be able to configure your browser to reject cookies, but doing so will limit the functionality and negatively impact your experience using the Site.

California Residents Privacy Rights:

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask certain businesses to respond to requests about the business practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We require you to expressly opt-in to any disclosure of your personal information to third parties for the third parties’ direct marketing purposes, which is stricter than required under California law. If you are a California resident and would like a copy of this Privacy Policy, please submit a written request to the address below.

Visiting the Site from outside the United States:

If you are visiting the Site from outside the United States, please be aware that your information will typically be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your personal information is protected. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including personal information, to the United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Users of the Site from the European Union (“EU”):

If your personal information is subject to the General Data Protection Regulation (“GDPR”), in the course of providing the Site to you, we may transfer your personal information outside of the EU, principally to OFS’s servers in the United States; this means that your personal information will not have the automatic protection of European data protection laws (including the GDPR) which apply in the EU. In these circumstances, in order to ensure that your personal information continues to have adequate protection when it is transferred outside the EU, your personal information will only be transferred on one of the following bases:

1. Where the transfer is subject to one or more of the appropriate safeguards for international transfers prescribed by applicable law (for example, standard data protection clauses adopted by the European Commission);
2. A European Commission decision provides that the country or territory to which the transfer is made ensures an adequate level of protection; or
3. There exists another situation where the transfer is permitted under applicable law (for example, where we have your explicit consent).

You can obtain more details of the protection given to your personal information when it is transferred outside the EU by contacting us using the details set out below.

Children’s Privacy:

Protecting the privacy of young children is especially important to us. For that reason, OFS does not knowingly collect or maintain personal information from children under 13 years of age. If OFS learns that the personal information of children under 13 years of age has been collected on or through the Site, OFS will take the appropriate steps to delete such personal information. If you are the parent or legal guardian of a child under 13 years of age who has become a registered user of the Site or otherwise has used the booking engine or our Services, please contact us by email at support@optimalfinancial.io to have your child’s transactions terminated and personal information deleted.

Third-Party Websites:

If the Site contains links at any time to other websites that are not operated by us and you click on any such third party link, you will be directed to such third party’s website. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party websites or services. We strongly recommend that you review the privacy policy of every website you visit.

Our Contact Information:

If you have any questions about this Privacy Policy or any concerns regarding the collection, use and disclosure of your personal information, or to instruct us regarding your choices regarding your personal information, you may contact us using any of the following ways:

By email:

support@optimalfinancial.io

By mail:

Optimal Financial Systems, LLC
429 Santa Monica Blvd., Suite 320
Santa Monica, CA 90401
Attention: Privacy Officer

We will attend to your questions, concerns, or instructions promptly.

Changes to our Privacy Policy:

We reserve the right to make changes to this Privacy Policy at any time and without prior notice to you. We will notify you of any changes to the Privacy Policy by updating the “Last Updated” date at the top of this Privacy Policy. Any changes to this Privacy Policy will be posted and become effective immediately. We encourage you to review the Privacy Policy periodically.

If you do not agree to the terms of this Privacy Policy or any revised Privacy Policy, please exit the Site immediately and discontinue your use of the Site.