www.Optimarrow.com

Privacy Policy

Last Revised: June 12, 2024 (“Effective Date”)

Policy Statement.

This Privacy Policy (this “Policy”) describes how Optimarrow LLC and its Affiliates (collectively, the “Company” or “We” or “Us” or “Our”) collect, use, disclose, and store information that you provide to Us. This Policy applies to Optimarrow.com (the “Site”) and any other website, application, service, platform on or in which the Site is posted linked or referenced. In addition to the Site, this Policy is intended to apply to Our routine data collection, use, storage, and disclosure of information in the ordinary course of conducting Our executive advisory and director services, which is an expansive term that might include and is not limited to, in addition to traditional advisory services and board director responsibilities and other contracted for services, the free or fee-bearing provision of subject matter research and guidance based on opinion, experience, or otherwise business (the “Services”).

Purpose.  

We believe it is important to conduct itself ethically wherever it does business, including being transparent with regard to its information collection, use, disclosure, and storage practices. This Policy describes:

·       Information We receive from you when you interact with the Site.

·       Information We receive from you when you interact with or receive Our Services.

·       How We use, process, and store the information We receive.

·       If and why Personal Information may be disclosed to third parties.

·       Your choices regarding the collection and processing of your Personal Information.

Please note, this Policy does NOT apply to information collected through third-party websites or services that you may access through the Site or in connection with the Services or that you may submit to Us through a third-party platforms that We do not control.   

Definitions. 

·       “Company” is defined as above in the Policy Statement.

·       “Cookies” means computer files sent to or accessed from your web browser or your computer's or tablet's hard drive that contain information about your computer (or computing device), such as a user ID, user settings, browsing history, and activities conducted while using the Site. Cookies are not personally identifiable but may be linked to Personal Information that you provide to Us through your interaction with the Site. A Cookie typically contains the name of the domain (internet location) from which the Cookie originated, the “lifetime” of the Cookie (i.e., when it expires) and a randomly generated unique number or similar identifier.

·       “Employee” means any full-time, part-time, and contractor staff of Company.

·       “Client Terms” means collectively and individually, Our Master Services Agreement, any schedules attached to or intended to be made part of Our Master Services Agreement, and any other similar but differently named agreement We may provide in connection with providing the Services other than the Online Terms.

·       “Location Data” as defined below in Location Data.

·       “Online Terms” means collectively and individually, Our Online Terms of Use and any other similar but differently named agreements We provide in connection with Site or in connection with Services provided directly through the Site without other interaction with Us.

·       “Personal Information” means any information, documents, records, and electronic data processed, stored or maintained by Us (i) that identifies or can be used to identify, contact, or locate the person to whom such information relates or (ii) from which identification or contact information of an individual person can be derived. Personal Information includes (1) contact data (such as e-mail address, telephone number and employer); (2) demographic data (such as gender, date of birth, and zip code); and, (3) Usage Data, but only to the extent such data may identify an individual or is required s required to be treated as Personal Information under applicable law.

·       “Policy” is defined as above in the Policy Statement.  

·       “Representative” means any Company employee, executive, director, member, consultant, contractor, or other third-party authorized to act in some capacity on behalf of Company.

·       “Usage Data” means information about an individual's online activity that, by itself, does not identify the individual, such as browser type, operating system, and webpages visited.

Consent. 

PLEASE REVIEW THIS POLICY CAREFULLY. When you submit information to or through the Site or in connection with receiving the Services, you consent to the collection and processing of your information as described in this Policy.

By using the Site or the Services, you accept the terms of this Policy and consent to Our collection, use, disclosure, and retention of your information as described in this Policy.

If you intend to receive our Services, please also carefully review our standard Client Terms. Each the Online Terms and the Client Terms contain provisions that limit our liability to you and the organization you represent. Other than purchases made directly through the Site (if applicable) or on or through third-party platforms (in which case you consent to the terms provided as part of the sale), Our Client Terms and the Services provided pursuant to such Client Terms will only be binding upon you and We will have no obligation to provide any Services to you until such terms are mutually accepted by Us and the organization you represent. Please note that due to the personal nature of Our Services, Our customer selection process is highly selective and We may reject any request to become a customer in our sole and absolute discretion.

IF YOU DO NOT AGREE WITH ANY PART OF THIS POLICY OR OUR ONLINE TERMS, THEN PLEASE DO NOT USE THE SITE OR ANY OF OUR SERVICES.

Data Types.

Sensitive Personal Information:

Certain Personal Information, such as information about personal health or finances, is characterized as sensitive and subject to stricter regulation than other Personal Information. As a practice, We do not collect sensitive Personal Information unless necessary to provide you with the Services you have requested or as required by applicable law. If We do collect sensitive Personal Information, We only retain such information as long as necessary to fulfill our legitimate business purpose. If you do provide sensitive Personal Information to us, you consent to its use and disclosure for the purposes and in the manner described in this Policy.

Location Data:

“Location Data” is a category of information, that may in some instances be Personal Information, collected about the location of a mobile device or computer, including:

·       the location of the mobile device or computer used to access the Site derived from GPS or WiFi use;

·       the IP address of the mobile device or computer or internet service used to access the Site;

·       precise geolocation data; and,

·       other information made available by a user or others that indicates the current or prior location of the user.

We may use Location Data for security purposes, to comply with applicable law and regulation (e.g. preventing web traffic from restricted countries), and when necessary to provide you with the Services you have requested; however, We will use reasonable means to notify you and obtain your express opt-in consent before collecting your Location Data.

Cookies:

We and the service providers that help us make the Site available to you use Cookies. Cookies may be session Cookies, which are erased when you close the web browser or turn off your computer, or Cookies may be persistent Cookies, which are stored until deleted from the web browser directory.

Cookies help Us improve the Site and the Services We provide by tracking users' navigation habits and (where applicable) storing users' passwords, customizing users' experience with the Site; enabling Us to analyze technical and navigational information about your use of the Site; and helping to detect and prevent fraud and other cyber-related risks or harm.

We use other Cookies and other data collection tools (such as web beacons and server logs), which We collectively refer to as “Data Collection Tools,” to help improve your experience with the Site and improve how We provide the Services. For example, Data Collection Tools help us remember users and make the Services more relevant to them.

The Site may also use Data Collection Tools to collect Usage Data and other information from the device used to access the Site, such as operating system type, browser type, domain and other system settings, as well as the operating system used and the country and time zone in which the computer or device is located.

In addition to your opt-out abilities, please note, many web browsers allow some level of control over most Cookies through the web browser’s settings. Some web browsers (including mobile web browsers) provide settings that allow you to reject Cookies or alert you when a Cookie is placed on your computer, tablet, or mobile device. Many mobile devices also offer you the ability to reject mobile device identifiers.

Although you are not required to accept Cookies or mobile device identifiers on the Site, if you choose to block or reject either, some areas of access or features of the Site may be limited or prevented.

Oversight & Management.

Changes:

This Policy’s Effective Date is set forth at the beginning of the Policy.  When possible and where practical, We will provide you with advance written notice of our changes to this Policy. We will not make retroactive changes that reduce your privacy rights unless We are legally required to do so. Your continued use of the Site or the Services after the Effective Date constitutes your acceptance of the amended Policy. The amended Policy supersedes and replaces all previous versions.

Combining Information:

We may combine the information We collect from you with information from other sources and use the combined information as described in this Policy. Similarly, We may aggregate and anonymize information you provide to Us, such as Usage Data, and use such information for our legitimate business purposes, which may include or be related to providing, analyzing, improving, expanding, and testing our Services and the Site.

General Information Collection:

We collect information that you provide to Us in connection with your use of the Site or the Services or that you may provide to Us from time-to-time. The information that We collect and how We process it depends on how you use and access the Site or use and access Our Services. Some information is collected automatically through use of Cookies and similar Data Collection Tools. To learn more about how and why We use Cookies and other Data Collection Tools to collect information, please review the Cookies Section above.

We collect information from you when you:

·       Use the Services: We collect Personal Information and Usage Data from you when you contract to use our Services or when you create an account on the Site to use one of the Services. Similarly, We collect Personal Information and Usage Date when you contact Us for help, contact Us for information, or otherwise voluntarily provide your Personal Information to Us.

·       Connect with Social Media though the Site: The Site may offer you the ability to make announcements through our Site on third-party social media services (collectively, “Social Media”). When you access your Social Media account through the Site, the Site may, depending on your privacy settings, have access to information that you have provided to the Social Media platform. We may use this information for the purposes described in this Policy or described at the time the information was collected.

·       From Our Business Partners and Service Providers: Third parties that assist Us with our business operations also collect information (including Personal Information and Usage Data) about you through the Site and share it with Us. For example, our vendors collect and share information with Us to help us detect and prevent fraud or other cyber-related risks or harm.

·       Usage Data: We automatically collect Usage Data when you interact with the Site (See Cookies Section).

·       Customer Satisfaction Surveys: We collect Personal Information from you when you complete and submit Customer Satisfaction Surveys or provide other customer feedback or suggestions or complete service or quality reviews.

·       Contracting with Us: We collect Personal Information when you contract with Us for one of the Services for notification purposes required by our Client Terms. Use of the Site will be subject to the Online Terms, which is different that the Client Terms entered into for on-going engagements for Our Services.

·       Creating an Account with Us: We collect Personal Information and Usage Data from you when you create an Account on the Site and Personal Information when you create an account pursuant to the Client Terms referenced above.

·       Joining Mailing Lists: We collection Personal Information from you when you choose to join Our mailing list, Our newsletter list, and other opt-in continued communication between Us and you.

·       Participating in Webinars & Online Education: We collect Personal Information from you when you sign-up for webinars, seminars, online education, or other live or recorded events that We may host or participate in.

Third-party Tracking.

Online Advertising:

Our advertising management partners (“Ad Partners”) use Data Collection Tools through the Site to enable them to recognize a unique Cookie that has been placed on a user's browser, which in turn enables Us and these Ad Partners to learn which advertisements bring users to the Site. In addition, We and Our Ad Partners may use these Data Collection Tools to track the actions of users of the Site, to measure statistics and metrics of Our marketing efforts, and to deliver advertisements on the Services that may be more relevant to you.

We and Our Ad Partners also may use Data Collection Tools to record the actions of users of the Site, to measure statistics and metrics of our marketing efforts, to deliver advertisements on the Services that may be more relevant to individual consumers, to improve our Services offering, to improve the consumer experience on the Site or related to the Services, and to improve the seller experience on the Site or related to the Services.

We support the Self-Regulatory Principles for Online Behavioral Advertising of the Digital Advertising Alliance (“Principles”). This means to the extent that We deploy behavioral advertising practices, We allow users to exercise choice regarding the collection of information about their online activities over time and across third-party websites for online interest-based advertising purposes.

Opting Out of Interest-Based Advertising:

To the extent We deploy interest-based advertising, Users may “opt out” of interest-based advertising by following the instructions at  www.networkadvertising.org/choices/. After opting out, an “opt-out” Cookie will be placed on the user's device indicating that the user does not want to receive interest-based advertisements. If a user deletes Cookies generally, the user will need to opt-out again.

Opting out of interest-based advertising does not mean users will no longer see advertisements from Us or on the Services; rather, opting out means that the online ads presented will not be based on the user's particular interests.

In addition, even after opting out of receiving interest-based advertisements, Data Collection Tools on the Site may collect information about users' activities on the Site, including for analytics, fraud prevention, cyber-related risk and harm, and any other purpose permitted under the Principles and applicable law.

Data Collection by Third Parties:

Certain third parties that We do not control may use Data Collection Tools on the Site or in relation to the Services. This Policy does not apply to those third parties or their Data Collection Tools.

How Information is Used.

We may use the information We collect for any of the following purposes:

·       to provide the Services to you;

·       to provide the Site to you;

·       to operate, improve, and personalize the Services We offer, and to give each user a more consistent and personalized experience when interacting with Us;

·       for customer service, security, and to detect fraud or illegal activities in connection with the provision of the Services;

·       for archival and backup purposes in connection with the provision of the Services;

·       for customer service, security, and to detect fraud or illegal activities in connection with the provision of the Site;

·       for archival and backup purposes in connection with the provision of the Site;

·       to communicate with users, such as responding to user inquiries, providing order updates, providing customer updates, sending newsletters, sharing marketing materials and information, and providing general information on the Company and Services;

·       to better understand how users access and use the Site and the Services;

·       for the purposes of trying to improve the Site and the Services;

·       to respond to user preferences, including language and location customization, personalized help and instructions, or other responses to users' usage of the Site or Services;

·       to help Us develop new products and improve existing products;

·       to help Us develop, supplement, augment, and improve Our Services;

·       to provide users with advertising and direct marketing that is more relevant to you;

·       to enforce Our Online Terms, Client Terms, or other applicable policies; and,

·       to assess the effectiveness of and improve advertising and other marketing and promotional activities in relation to the Services.

Please note that for the purposes of seeking to provide Our users with a better experience and to improve the Site and Services, information collected through the Site or the Services may, subject to user privacy controls (if available), be used in an aggregated or individualized manner.

For example, personal information collected during use of one of the services may be used to suggest particular content that can be made available to the user on the Site or different products provided through the Services or be used to try to present more relevant advertising related to the Services.

Sharing or Disclosure of Information.

We may share information as described at the time the information is collected or as follows:

To Perform Services: 

We may disclose Personal Information to third parties in order to perform Services requested or functions initiated by users, such as to fulfill shipping requests and instructions. In addition, We may disclose Personal Information in order to identify a user in connection with communications sent through the Site or in relation to the Services. We also may offer users the opportunity to share information with friends and other users through the Site.

With Third Party Service Providers Performing Services on Our Behalf: 

We share information, including Personal Information, with Our service providers to perform the functions for which We engage them (such as hosting and data analyses). We may share information as required to operate our Services.

For Legal Purposes: 

We may share information that We collect from users, as needed, to enforce Our rights, protect Our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance, and corporate governance functions. We will disclose Personal Information as We deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request, or other legal or regulatory process. We may also share Personal Information as required to pursue available remedies or limit damages We may sustain.

Corporate Changes: 

We may transfer information, including your Personal Information, in connection with a merger, sale, acquisition or other change of ownership or control by or of Us or any affiliated company (in each case whether in whole or in part). When one of these events occurs, We will use reasonable efforts to notify users before your information is transferred or becomes subject to a different privacy policy.

Information Transfer:

We may transfer information about you, including your Personal Information, in connection with a merger, sale, reorganization, acquisition, or other change of ownership or control by or of the Company or any affiliated company (in each case, whether in whole or in part). When one of these events occurs, we will use reasonable efforts to notify users before their information becomes subject to different privacy and security policies and practices.

How to Manage Your Information:

If you have any questions about how to access your Personal Information, please contact Us at info@optimarrow.com. You can also contact Us at help@optimarrow.com to manage and correct the information We have on file about you.

How Information is Retained & Disposed:

We retain information for so long as it is necessary and relevant for Our operations. In addition, We retain Personal Information to comply with applicable law, comply with our contractual obligations, prevent fraud and other cyber-related risk and harm, resolve disputes, troubleshoot problems, assist with any investigation, enforce Our Online Terms, enforce our Client Terms, collect any fees owed, and other actions permitted by law. After it is no longer necessary for Us to retain information, We dispose of it according to our data retention and deletion policies.

How Information is Secured:

We employ industry standard security measures reasonably designed to protect the security of all information submitted through the Site and Services. However, it is important to understand that the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of Our Site. In order to protect you and your data, We may suspend your use of any area of the Site or any of the Services, without notice, pending an investigation, if any breach of security is suspected. Access to and use of password protected or secure areas of any of the Site are restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution.

Linked Services:

The Site may contain links to third-party websites and services (“Third-Party Services”) with which We have no affiliation. A link to any Third-Party Service does not mean that We endorse the third-party or the quality or accuracy of information presented on the third-party’s site or services. If you decide to visit a Third-Party Service, you and your use are subject to its privacy policy and practices and not this Policy. We encourage you to carefully review the legal and privacy notices of all other digital services or sites that you visit.

Special Provisions.

Not Child Directed:

The Site is not intended for use by children. If you are under the age of majority in your place of residence, you may use the Site only with the consent of or under the supervision of your parent or legal guardian.

Consistent with the requirements of the Children's Online Privacy Protection Act (COPPA), if We learn that We have received any information directly from a child under age 13 without first receiving his or her parent's verified consent, We will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Site and subsequently We will delete that information.

How We Respond to Do Not Track:

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to digital services that a visitor does not want to have their online activity tracked. If a digital service that responds to a particular DNT signal receives the DNT signal, the browser can block that digital service from collecting certain Personal Information about the browser's user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, We, like many other digital service operators do not currently respond to DNT signals.

EU Personal Information Processing:

Any Personal Information collected about EU visitors through the Site or in connection with providing the Services is processed in the United States by Us or by a party acting on Our behalf. When you provide Personal Information to Us through the Site and in connection with the Services, you consent to the processing of your data in the United States. The Services are hosted in the United States.

When appropriate, We enter into and adhere to the EU’s model contractual clauses with Our customers through our Client Terms.