Privacy Policy

Last Revised: July 12, 2021

Onbord Inc. (“Company”) makes the client onboarding process simple and efficient for registered investment advisors (“RIA(s)”). This Privacy Policy describes how your personal information is collected, used, shared, and safeguarded when you access Company’s mobile applications, websites, services, or products (collectively, the “App”). Any personal information that you provide to RIAs via the App is collected on behalf of and for the sole benefit of the applicable RIA(s) and is subject to their privacy and security practices and policies. Company does not process or disclose your personal information for any purpose other than to provide its services to RIAs.

Please read this Privacy Policy carefully. By using the App, you consent to the collection and use of your personal information by us as set out in this Privacy Policy. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, YOU ARE NOT PERMITTED TO USE OR ACCESS THE APP.

Personal Information We Collect

When you interact with the App, we may automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you use the App, we may collect information about the individual web pages that you view, what websites or search terms referred you to the App, and information about how you interact with the App. We refer to this automatically-collected information as “Device Information.”

We collect Device Information using the following technologies:

Additionally, we may collect certain personal information that you provide to us via the App from time to time, such as your name, telephone number and email address.

You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the App. You may not send us any sensitive personal information (e.g., social security number, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the App or otherwise.

How Do We Use Your Personal Information?

We and our service providers use personal information for our legitimate business purposes, including those specifically described below. We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation and/or because we have a legitimate business interest.

We use the personal information that we collect generally to fulfill any requests made through the App. Additionally, we use personal information to communicate with you, personalize your experience on the App, and, when in line with the preferences you have shared with us, provide you with information or advertising relating to Company and/or RIAs, which may include their products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize the App (for example, by generating analytics about how our users browse and interact with the App.

Sharing Your Personal Information

We may share your personal information with third parties to help us use your personal information, as described above. With your consent, on behalf of the RIA(s), we may share your personal information with third parties for marketing purposes, as permitted by law. We may share your personal information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates may include a parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us. We may share your personal information with advertisers and actual and potential investors for the purpose of conducting general business analysis. If we reorganize or sell all or a portion of our assets, undergo a merger or are acquired by another entity, we may transfer your personal information to the successor entity. If we go out of business or enter bankruptcy, your personal information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy. Finally, we may also share your personal information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

Do Not Track

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will revise this Privacy Policy accordingly.

Jurisdiction and Cross-Border Transfer

Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the App you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.

Options Regarding Your Personal Information

If you would like to delete, update, or access the personal information we have collected from you, you can send an email to us at support@onbord.io. We will delete your personal information from our active databases following your verified request, however, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our terms of service, and/or comply with legal requirements.

Emails and Other Communications

If you no longer wish to receive communications (including, without limitation, email and SMS/MMS messages) from us, you may opt-out by emailing us at support@onbord.io. If you no longer wish to receive communications (including, without limitation, email and SMS/MMS messages) from a third party (including the RIA(s)), you are responsible for contacting the third party directly.

Data Retention

We will retain your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include the length of time we have an ongoing relationship with you, when we have a legal obligation to which we are subject, or as advisable in light of legal requirements.

Third-Party Websites

The App may contain links to third-party websites and applications of interest that are not affiliated with us. Once you have used these links to leave the App, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot protect the safety and privacy of information that you provide to a third party outside of the App. Before visiting and providing any information to any third-party websites or applications, you should inform yourself of the privacy policies and practices (if any) of the third-party responsible for that website or application, and should take those steps necessary to, in your discretion, protect the privacy of your personal information. We are not responsible for the content or privacy and security practices and policies of any third parties (including the RIA(s)), including other sites, services or applications that may be linked to or from the App.

Security of Your Personal Information

We use administrative, technical and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information to us.

Changes

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last Revised” date at the top of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the App, and you waive the right to receive specific notice of each such change or modification. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the App after the date such revised Privacy Policy is posted.

Minors

The App is not intended for individuals under 18 years of age. We do not knowingly solicit information from or market to individuals under 18 years of age. If you become aware of any data we have collected from individuals under 18 years of age, please contact us using the contact information provided below.

California Residents

Under the California Consumer Privacy Act of 2018 (“CCPA”), Company is a “service provider” of the applicable RIA(s), which may be a “business” covered by the CCPA. As a “service provider”, Company processes your personal information in order to provide its services to the RIA(s), and in order to facilitate your interactions with the RIA(s). To learn more about rights that you may have under the CCPA, such as the right to request information about the types of your personal information that has been collected, the right to request that your personal information be deleted, and the right to opt-out of the sale of your personal information, please contact the applicable RIA(s).

Company and the App comply with the CCPA and other applicable laws. If you’d like to make a request to Company regarding your personal information, please contact us by e-mail at support@onbord.io, and we will reasonably try to accommodate your request unless we are prevented from doing so as a result of applicable law or a significant legitimate interest of Company. Please also note that, depending on the nature of your request, the fulfillment of your request may hinder or prevent Company’s ability to provide you with certain features and functionalities of the App.

Contact Us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at support@onbord.io or by mail using the details provided below:

Onbord Inc.
272 Ruth Road
Harleysville PA 19438