PRIVACY POLICY


OpenMarkets is concerned about your privacy. The nature of the services provided on the Website requires that OpenMarkets collects and uses certain information about you. This Privacy Policy explains what personal information OpenMarkets collects from you from the Website, the manner in which OpenMarkets collects it, and the purposes for that collection. This Privacy Policy is designed to ensure that you are aware of how your personal information is being used and to provide you with choices about that use. By visiting the Website or submitting your personal information, you accept the terms described in this Privacy Policy. This Privacy Policy applies to information collected via the www.openmarkets.com Website and does not apply to information gathered through the OpenMarkets application, CAP Connect. The terms and conditions of the Client Subscription Agreement controls the collection and use of information entered into the OpenMarkets application, CAP Connect.

COLLECTION OF PERSONAL INFORMATION
When you register on our Website, we will ask you for certain personal information such as, for example, your address, telephone number, and e-mail address. If you send OpenMarkets any correspondence, such as emails, letters, or requests for technical support, OpenMarkets may retain the information they contain. If any third parties provide information to us about you, we will treat that information in accordance with this Privacy Policy.

You may choose to disclose or not disclose the personal information we request during the registration process; however, if you choose not to disclose the requested information, we may not be able to provide you with some or all of the information or services you request.

AUTOMATED INFORMATION COLLECTION
OpenMarkets automatically tracks certain information about you based upon your behavior while visiting the Website. This information is used to better understand and serve you by responding to your particular interests and needs. This information may include the Uniform Resource Locator (URL) that you just came from (whether this URL is on the site or not), which URL you next go to (whether this URL is on the site or not), what browser you are using, and your IP address. OpenMarkets may collect this information and may store this session information about you on our system. Any such information associated with you personally is subject to this Privacy Policy.

You can turn off the ability to receive any of these cookies by adjusting the browser on your computer. Most browsers offer instructions on how to reset the browser to reject cookies in the "Help" section of the toolbar. If you refuse cookies, however, certain functions and conveniences of the Website may not work properly.

HOW WE USE YOUR INFORMATION
We use the information collected automatically to obtain general statistics regarding the use of the Website and its specific web pages and to evaluate how our visitors use and navigate the Website. For example, we may calculate the number of people who use the Website, open our emails, and determine which pages are most popular.

OpenMarkets uses the information you provide through the registration process to provide you with the information and services you request, to communicate with you on matters relating to the Website and your account, to provide necessary information to accrediting or certifying bodies, and other of our business affiliates (but only in connection with the information and services you request from us) to provide you with information about related services and/or products.

OpenMarkets may also use information about you to resolve disputes, troubleshoot problems, or enforce our rights. At times, OpenMarkets may review the information of multiple users to identify problems or to resolve disputes.

Opt-Out Policy: If you do not wish to receive certain communications from OpenMarkets you may opt out by declining the service offered or informing us that you no longer wish to receive such communications. We will comply with your request unless such communications are necessary for the administration of your account, required by law, or necessary to protect our rights.

SHARING WITH THIRD PARTIES
Some of your private information may be disclosed to third parties in order to provide the information and services that you request, and may be used by both OpenMarkets and third parties to provide that information and/or perform those services. You acknowledge that certain activities may require OpenMarkets to share your private information, and/or the activity’s results with the associated third party accreditor or entity providing board certification. We are not responsible for the use of any such information by such third party accreditor or entity providing board certification, including use by any of the same in a manner not intended when such information is disclosed to them.

We may combine, in a non-personally-identifiable format, the information that OpenMarkets collects from you with information from other users to create aggregate data, which may be used by us for research purposes or shared with third parties. For example, OpenMarkets might inform third parties regarding the number of users of our Website and their collective interaction within the Website.

The aggregate data that we may share does not contain any information that could be used to identify or contact you, and we require parties with whom we share aggregate data to agree that they will not attempt to make this information personally identifiable, such as by combining it with other databases. We will not disclose your personal information to any third party without your prior permission, except as otherwise permitted by this Privacy Policy or the End User License Agreement into which it is incorporated by reference.

OTHER DISCLOSURE
Technical and legal circumstances beyond our control could prevent OpenMarkets from ensuring that your information will never be disclosed in ways not otherwise described herein. For example, among other things, we may be required by law, regulation or court order to disclose information to government representatives or third parties under certain circumstances. If OpenMarkets is requested by law enforcement officials or judicial authorities to provide information on individuals, OpenMarkets may, without your consent, provide such information. In matters involving claims of personal or public safety or in litigation where the data is pertinent, OpenMarkets may use or disclose your personal information without your consent or court process. Unauthorized parties may unlawfully intercept or access transmissions despite any commercially reasonable security efforts by OpenMarkets. Even with such technology, no website is 100% secure. Further, corporate restructurings, sale of assets, merger, divestiture and other changes of control or financial status affecting the Website may require disclosure as an incidental result of a transfer of assets by operation of law or otherwise. Therefore, OpenMarkets does not promise, and you should not expect, that your private information shall remain private under all circumstances and you shall not hold OpenMarkets or its business associates liable for its failure to do so.

YOUR RIGHTS
You may at any time print, download, or request a printed copy of this Privacy Policy or the End User License Agreement into which it is incorporated by reference.

SECURITY
OpenMarkets uses commercially reasonable efforts to ensure the security of your personal information, but no method of transmitting or storing electronic data is ever completely secure, and OpenMarkets cannot guarantee that your information will never be accessed, used, or released in a manner that is inconsistent with this policy.

TRANSFER OF DATA OUTSIDE YOUR HOME COUNTRY
Your information will be stored, processed, and accessed in the United States. If you use the Website from outside of the United States, you consent to the transfer of your information to the United States (i.e., outside your country of residence).

CHANGES TO THIS POLICY
From time to time OpenMarkets may modify this Privacy Policy. You can view the most recent version of the Privacy Policy at any time by clicking the “Privacy Policy” link at the bottom of pages on the Website. Your continued use of the Website after any modification indicates your agreement to the new terms.

CONTACT US
If you have any questions that are not answered elsewhere on this site, if you would like to review the personally identifiable information we have collected about you, or if you believe that this policy has been violated, please contact Michael Fineberg at (866) 447-3270 or mfineberg@openmarketshealth.com. Our response to such in inquiries may be limited to information under our direct control.




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