Privacy Policy
The privacy practices of this Online Privacy Policy apply to Obra Capital’s (the “Company”) services available under the domain and subdomains of Obra.com (the “Website”). We recognize that privacy is important to our users, so we design and operate our Website with the protection of your privacy in mind. This Online Privacy Policy outlines the types of personal information we may gather when you visit our Website or use our services, as well as some of the steps we take to safeguard it. Please read this Online Privacy Policy to learn more about the ways in which we protect, use and disclose your personal information. By visiting the Website, you agree to be bound by the terms and conditions of this Online Privacy Policy. If you do not agree, please do not use or access the Website. By accepting the Online Privacy Policy and the Terms of Use, you expressly consent to our use and disclosure of your personal information in accordance with this Online Privacy Policy. This Online Privacy Policy is incorporated into and subject to the Terms of Use. This Online Privacy Policy is effective when accepted by new users, and is otherwise effective on November 1, 2010, for all users.
OVERVIEW
We have adopted general policies and procedures concerning confidentiality, proprietary data and privacy of customer personal information, and the information we gather over the Website is protected by those policies and procedures. Generally, we collect non-public personal information about our clients and investors from the following sources:
Information received from clients or investors on applications or other forms, including the information we collect on the Website, and
Information about clients’ or investors’ transactions with us, our affiliates or others.
OUR POLICY IS THAT:
We do not disclose any non-public personal information about our current or former clients or investors to anyone, except as permitted by law. We share non-public personal information with certain service providers, to the extent permitted by law, and we require those service providers to keep the non-public information confidential.
We restrict access to non-public personal information about our clients and investors to employees and service providers who need to know that information to provide services to our clients.
We maintain physical, electronic and procedural safeguards that comply with federal standards to guard clients’ and investors’ personal information.
COLLECTION OF INFORMATION
If you apply for a password to access password-restricted areas on this Website, you must provide to us your name, mailing address, email address, phone number, personal financial data, investment portfolio and other investment information.
MARKETING COMMUNICATIONS
To the extent that users of this website voluntarily provide information to the Company through the website, such information will be kept confidential and used only for providing information or responding to the user’s inquiry. By submitting your contact or identifying information, including your name, phone number, address and email address, you understand that we may contact you by email, mail or phone to discuss your inquiry and you consent to this contact. You agree that all agreements, notices, disclosures, and other communications that the Company provides to you in accordance with the prior sentence satisfy any legal requirement that such communications be in writing.
INTERNET COOKIES
Cookies are text files placed on your device by websites to collect standard log information and visitor behavior information. Use of cookies makes using the Internet easier and use of cookies is an industry standard.
Our service providers and we use cookies on our website. Information from cookies is used to track your use on our websites and to make statistical reports on activity on our website. For more information about cookies visit www.aboutcookies.org or All About Cookies.org at http://www.allaboutcookies.org/.
Your browser is probably set to accept cookies. However, if you would prefer not to receive cookies, you can change your browser settings to refuse cookies and www.aboutcookies.org will tell you how to remove cookies from your browser. If you choose to have your browser refuse cookies, it is possible that some areas of our website will not work properly when you visit them.
MORE ABOUT COOKIES
This More About Cookies section outlines, for each cookie that is set on your device when you visit this website, its purpose, information collected when you visit this website and third-party sites, how to opt out, and a link to a website where you can withdraw consent to being tracked by third parties. Session cookies are automatically deleted at the end of your browsing session. Persistent cookies remain on your device for the duration of each specific cookie, until its expiration date or until you delete it, whichever comes first. Unless otherwise stated, the cookies listed below are persistent.
Each cookie serves one of three different purposes: essential, service enhancement, or analytics. The cookies on this site will not be used for any purpose other than as stated below.
ESSENTIAL COOKIES
Essential Cookies are necessary for the operation of this website because they enable you to freely move through the Site. If you do not permit the use of Essential Cookies, your visit to this Site may be impaired. For example, these cookies remember your preferences as you move around the Site.
SERVICE ENHANCEMENT COOKIES
Service Enhancement Cookies store your preferences and enable the Company to provide the functions and contents of this website tailored to your specific needs. In addition, these cookies can be used to enable videos on this website and enable sharing with social networks. Information that may be collected includes:
Analytics, Browser Information, Cookie Data, Date/Time, Demographic Data, Hardware/Software Type, Internet Service Provider, Page Views
IP Address, Device ID, Search History
Name, Address, Phone Number, Email Address, Login
Financial Information
ANALYTICS COOKIES
Analytics Cookies collect data on how this website is used, for example which pages of the website were most frequently visited. These cookies provide the Company with analytical data on the performance of this website and information regarding how to improve it.
GOOGLE UNIVERSAL ANALYTICS
We use Google Analytics which is a web analytics service from Google, Inc. Google Analytics sets a cookie on your device for the purpose of recognizing your device. We use the data received from Google Analytics for business planning, operations, and marketing activities aimed at understanding better how to improve the contents of our website and your user experience. While the cookie is persistent, the data expires in two years. Information that may be collected includes:
Analytics, Browser Information, Cookie Data, Date/Time, Demographic Data, Hardware/Software Type, Internet Service Provider, Interaction Data, Page Views, Serving Domains
IP Address, Device ID, Search History, Location Based Data
Name, Address, Phone Number, Email Address, Login
For more information about how Google collects, uses and shares your information, please visit the Google Privacy Policy-Partners website at http://www.google.com/policies/privacy/partners/
BING ANALYTICS
We use Bing Analytics which is a web analytics service from Microsoft, Inc. Bing Analytics sets a cookie on your device for the purpose of recognizing your device. We use the data received from Bing Analytics for business planning, operations, and marketing activities aimed at understanding better how to improve the contents of our website and your user experience. Information that may be collected includes:
Analytics, Browser Information, Cookie Data, Date/Time, Demographic Data, Hardware/Software Type, Internet Service Provider, Interaction Data, Page Views, Serving Domains
IP Address, Device ID, Search History, Location Based Data, Clickstream Data
Name, Address, Phone Number, Email Address
For more information about how Bing collects, uses and shares your information, please visit the Microsoft Privacy Statement website at https://privacy.microsoft.com/en-us/privacystatement
ADVERTISING COOKIES
Advertising Cookies collect information about your visit to this website for the purpose of retargeting (showing you the Company’s ads on other websites) and behavioral advertising (showing you ads on other websites based on your browsing history). These cookies help the Company understand which online advertising is working to bring visitors to this website before or after they have seen the Company’s digital advertisement.
Taboola. Information collected could include:
Ad Views, Analytics, Cookie Data, Date/Time, Demographic Data, Hardware/Software Type, Page Views
IP Address, Device ID, Location Based Data, Device ID
Name, Address, Phone Number, Email Address, Login
Financial Information
Amobee / Turn. Inc. Information collected could include:
Ad Views, Analytics, Browser Information, Cookie Data, Date/Time, Demographic Data, Hardware/Software Type, Page Views
IP Address, Device ID, Search History, Location Based Data, Device ID
Name, Address, Phone Number, Email Address
Gamut Media. Information collected could include:
Browser Information, Cookie Data, Date/Time, Interaction Data, Page Views
IP Address, Device ID, Search History
Name, Address, Phone Number, Email Address, Login
Financial Information
Krux Digital is a tracking pixel placed on behalf of Pulpo. Information collected could include:
Browser Information, Cookie Data, Date/Time, Demographic Data, Hardware/Software Type, Internet Service Provider, Interaction Data, Page Views, Serving Domains
IP Address, Device ID
Name, Address, Phone Number, Email Address
Sojern. Information collected could include:
Browser Information, Date/Time, Hardware/Software Type, Internet Service Provider, Page Views
IP Address, Device ID, Search History
Name, Address, Phone Number, Email Address
Pinterest. Information collected is subject to your Pinterest account settings.
Facebook. Information collected is subject to your Facebook and/or Instagram account settings.
Google Ad Word Tracking. Information collected could include:
Ad Views, Analytics, Browser Information, Cookie Data, Date/Time, Demographic Data, Hardware/Software Type, Internet Service Provider, Interaction Data, Page Views, Serving Domains
IP Address, Device ID, Search History, Location Based Data
Name, Address, Phone Number, Email Address, Login
HOW TO CONTROL COOKIES
You can control and/or delete cookies as you wish – for details, see aboutcookies.org, and www.youronlinechoices.com.
We use Google Analytics and Bing Analytics, to help the Company measure visitors and trends for this website. For more information about how Google collects, uses and shares your information, please visit the Google Privacy Policy-Partners website at http://www.google.com/policies/privacy/partners/. For more information about how Bing collects, uses and shares your information, please visit the Microsoft Privacy Statement website at https://privacy.microsoft.com/en-us/privacystatement/.
To prevent your data from being used by Google Analytics, click here for instructions.
You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed on your device. If you do this, however, you may have to manually adjust some preferences every time you visit this website and some services and functionalities may not work. Note that when you opt-out of being tracked and/or targeted by some companies, they set a cookie in your browser to indicate that you have opted out.
If you want to opt-out of targeted interest-based online advertising, please visit Network Advertising Initiative (NAI) Consumer Opt-Out website at http://www.networkadvertising.org/managing/opt_out.asp. Please note you will continue to receive generic ads.
OTHER WEBSITES AND SOCIAL MEDIA
This website may contain links to other websites. This Online Privacy Policy only applies to the Company’s website, so when you visit or use other websites you should read their own privacy policies.
The Company’s website and communications may contain links to social media websites such as Facebook, LinkedIn, Twitter, etc., and social media features, such as the Facebook “Like” and “Share” buttons. Social media sites and features may collect and use Personal Information from you. We have no control over and are not responsible for the privacy practices, policies, or content of any Social Media websites or features, even if you link to them from, or use them on this website. Please review Facebook’s privacy policy at https://www.facebook.com/about/privacy/update . Please review LinkedIn’s privacy policy at https://www.linkedin.com/legal/privacy-policy . Please review Twitter’s privacy policy at https://twitter.com/privacy. Please review Instagram’s Privacy Policy at https://help.instagram.com/519522125107875. Please review Pinterest’s Privacy Policy as https://policy.pinterest.com/en/privacy-policy.
We are not responsible for information, content, and/or the privacy practices of Third Parties operating websites that may link to this website. The inclusion of a link on this website does not imply endorsement of the linked site by the Company or by our business partners.
USE AND DISCLOSURE OF INFORMATION
We use the information we collect from our browser and data collection devices such as cookies to improve our operations and facilitate the services you request. We may use information collected from you to measure interest, customize your experience and enforce our Terms of Use. If you apply for a password, we use that data to determine whether you are an accredited investor and have sufficient sophistication, investment experience and wealth to receive information about certain investment options. We may use your information to send correspondence and perform services on your behalf in connection with investment related activities. In connection with providing our services, it also may be necessary for us to share information with other third parties to help us process transactions relating to your account, including, but not limited to, asset transfers from a financial institution and processing or administering investment transactions and portfolios. In certain instances, we may contract with third parties that are not affiliated with us to perform services for us, and, if necessary, we may disclose information about you to those third parties solely for the purpose of carrying out their assigned responsibilities. In those circumstances, we require such third parties to treat your private information with the same degree of confidentiality that we do. In some instances, the third-party service provider may collect information directly from you. In these cases, you will be notified of the involvement of the service provider, and all additional information you provide them and their additional uses will be strictly up to you. If you provide additional information to a service provider directly, their use of your personal information is governed by their applicable privacy policy. We may also share information about you if we believe that disclosure is required under law. For example, we may need to disclose information in response to a subpoena or to cooperate with regulatory or law enforcement authorities. We cannot ensure that all of your private communications and other personal information will never be disclosed in ways not described in this Online Privacy Policy. For example (without limiting the foregoing), we may be forced to disclose personal information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or service providers may abuse or misuse your personal information that they collect from the Website. Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private.
CONTROL OF YOUR PASSWORD AND PERSONAL INFORMATION
You are responsible for all actions taken with your user name and password. Therefore, we recommend that you do not disclose your password to anyone. You may not allow others to use your user name or password to access or use any part of this Website. If your password has been compromised for any reason, you should contact us immediately for a new password. You can review and change the information that you submit to us by contacting us at investorservices@Obra.com. You can change your User ID, email address, contact information, financial information, other personal information and user preferences. You must promptly update your personal information if it changes or is inaccurate. On your request, we will deactivate your password and remove your contact information and financial information from our active databases. Your password will be deactivated promptly based on your account activity and in accordance with our deactivation policy. We will retain in our files the personal information you have asked us to remove from our active databases to prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms of Use and comply with legal requirements. Therefore, you should not expect that your personal information will be completely removed from our databases in response to your requests. However, such personal information will only be available to select employees, service providers and governmental persons or entities.
SECURITY
Your information is stored on our servers located in the United States. We use procedural and technical safeguards to protect your personal information against loss or theft as well as unauthorized access and disclosure to protect your privacy, which may include encryption, “firewalls” and Secure Socket Layers. We treat data as an asset that must be protected against loss and unauthorized access. We employ security techniques to protect such data from unauthorized access by users inside and outside the company. However, “perfect security” does not exist on the Internet.
CHILDREN
Persons under age 18 are not eligible to use the Website.
CONDITIONS OF USE
If you choose to visit the Website, your visit and any dispute over privacy is subject to this Online Privacy Policy and our Terms of Use, including limitations on damages and application of the law of the State of Texas. If you have any concern about privacy, please send a thorough description.
CHANGES TO THIS POLICY
This Online Privacy Policy may change from time to time. We may amend this Online Privacy Policy at any time by posting the amended terms on the Website. All amended terms shall automatically be effective 30 days after they are initially posted on the Website.