This Privacy Policy (“Policy”) describes how Openn North America Inc. (“Openn”, “we”, “our”, or “us”) collects, uses, and discloses the Personal Information that we collect about you when you visit our website, www.openn.com (the “Website”), the Openn Negotiation mobile application (the “App”), or otherwise interact with our products and offerings (collectively referred to as the “Services”). We hope that this Policy will assist you to make informed decisions about sharing information with us and using our Services.
 
By accessing or using our Website or Services, you agree to the Policy and our Terms of Service located at https://www.openn.com/terms-of-service. If you do not agree with this Policy, you should not use our Website, App or Services. Your continued use of our Website, App or Services after we have made changes is deemed an acceptance of those changes, so please check the Policy periodically for updates.
 
We treat any data that identifies you, or reasonably can be linked to you, as “Personal Information.” Data that has been de-identified or aggregated so that it cannot reasonably be linked to you is not Personal Information, and we may use that data for any purpose.
 
Personal Information We Collect From You

We attempt to only collect Personal Information necessary to provide you with our industry leading products and services, and that Personal Information may include:
  • Contact and Identifying Information, such as name, postal address, date of birth, phone numbers, and email addresses.
  • Internet or Similar Network Activity, such as your IP address and activity on our Website or App, as well as your interaction with our advertising and other communications.
  • Commercial Information, such as information relating to your purchases and services, and purchasing or consuming histories or tendencies.
  • Location Information, such as information collected when you access our Website or App.
  • Demographic or Professional and Employment Information, such as information received by us in conjunction with utilizing our Services.
  • Financial Information, such as a credit or debit card account, or financial account for purposes of obtaining Services from us.
  • Inferences, such as any inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, or attitudes
How We Obtain Your Personal Information

  • From You:   We may obtain Personal Information that we collect about you from you when you interact with our Services, including when you: (1) contact and communicate with us, including through our service center or customer surveys, and (2) use or purchase our Services, including our Website or App, by taking actions such as: (a) registering to bid on a property, (b) listing a property to sell, or (c) participating in promotions. At your direction, we may also receive information from your representatives, such as attorneys, accountants and financial advisors.
  • From Public Data Sources: We may obtain information from public data sources, including, for example, regarding your home or your mortgage.
  • From Service Providers: Third party service providers may supply us with information needed for core aspects of our Services, which allows us to provide a better service experience for our clients. These third-party service providers include credit reporting agencies, data processors and aggregators and public record databases.
  • From Partners: We may obtain Personal Information about you from our partners who assist us to provide you with our Services. For example, we may receive information from real estate agencies or brokers, as well as third parties providing advertising or mailing lists.
Our Use of Personal Information

We may use your Personal Information as follows:
  • Provide Our Products and Services: We use Personal Information to furnish our Services and to improve the quality, safety and security of those Services, including to verify your identity. We also may use information to check your eligibility for our Services.
  • Communicate with You: We use Personal Information to respond to communications, contact you about transactions, promote our Services, provide other relevant information, and request information or feedback.
  • Internal Research: We use Personal Information to conduct internal research to develop, improve or repair our products, services or technology.
  • Security or Fraud Prevention: We use Personal Information to: (1) prevent, detect, protect against, or respond to security incidents, and (2) preserve the integrity or security of systems.
  • Legal Compliance: We may use Personal Information to comply with applicable law or to comply with a lawful governmental request.
We strive to retain your Personal Information only for as long as necessary to fulfill the purpose(s) for which we obtained the information or as otherwise required by law or contractually required by partners.
 
Our Sharing of Personal Information
 
We may share any of the categories of Personal Information that we collect above with service providers who act on our behalf, our partners, or others operating at your direction or where legally necessary or appropriate. We do not share Personal Information with third parties for their own marketing purposes.
 
  • Service Providers: We engage third parties to act as our service providers and perform certain tasks on our behalf in connection with delivering you our Services. The tasks performed by service providers include: (1) processing and storing Personal Information, (2) assisting with marketing communications and advertising, (3) processing credit card or other financial charges, and (4) providing technology services, including to assist with our Website or App. We may provide service providers with all types of Personal Information described above. We take reasonable steps to ensure that our service providers are contractually obligated to keep Personal Information confidential and only utilize the Personal Information as permitted.
  • Partners: We may share Personal Information with third party partners who assist to provide services and other offerings.  For example, we may share the types of Personal Information described above with our real estate industry partners for the provision of Services. Upon your request, we may also share your information with our other service partners to provide products or services of interest to you. We take reasonable steps to ensure that the entities to whom we share your Personal Information keep the information confidential and only use it as permitted.
  • Other Legal Purposes: We also may share Personal Information: (1) with your consent, (2) to respond to subpoenas, court orders, or other legal process or otherwise as required or allowed by law or the competent governmental or judicial authorities; (3) to cooperate with law enforcement, government or regulatory entities, and safety or investigation authorities; (4) to establish or preserve a legal claim or defense; or (5) as part of a corporate restructuring, sale of assets, merger or divestiture. 
Use of Cookies
 
When you visit our Website, our server may attach a “cookie” to your computer’s memory. A “cookie” assists us to store information on how visitors to our Website uses it, to identify you between multiple visits, and identify the pages that may be of most interest. This information may be used to make assumptions about who uses your computer and to provide users of your computer with information that we think may interest the users of your computer. We may link this information to Personal Information we hold about you. If we do, that information will become Personal Information, and will be treated in the same manner as the Personal Information to which it was linked. You should be able to configure your computer so that it disables “cookies” or does not accept them.
 
Security of Your Personal Information
 
We use commercial reasonably physical, technical and administrative security measures to reduce the risk of loss, misuse, unauthorized access, and disclosure. Please note, however, that no security measures are perfectly secure, and we are unable to guarantee the security of your Personal Information.
 
Third Party Websites and Applications
 
Our Website or App may contain links to websites or applications hosted by third parties. This Policy only applies to websites and applications within our control and does not apply to any third party sources. Any data collected through third party websites or applications shall be subject to the privacy practices of the third party, and you should review the privacy policies of these third parties prior to sharing any data.
 
Your Rights and Choices
 
Your choices regarding our use of your Personal Information for marketing
 
We give you certain choices regarding our use and disclosure of your Personal Information for promotional purposes. You may opt-out from receiving electronic communications from us by contacting us at the information contained in the “Contact Us” section below. If you no longer want to receive promotional-related emails from us, you may opt-out according to instructions in such communications. Please note that if you opt-out of receiving marketing-related messages, we may still send you important administrative messages.
 
Access, change or deletion of Personal Information
 
To the extent the rights are provided to you by applicable law, if you would like to request to review, correct, update, or delete Personal Information that you previously have provided to us, please contact us at the information contained in the “Contact Us” section below. We will respond to your request consistent with applicable law. Please note that we may act as a service provider in various functions, and that requests to correct, update, or delete Personal Information may be transferred to a data controller to respond accordingly.
 
Rights of EU Data Subjects
 
Use of Personal Information
 
We generally act as a data controller of your Personal Information submitted to us. We rely on your Personal Information for the legitimate commercial purposes of providing our products and services to you. Where we need to collect Personal Information by law or under the terms of a contract we have with you, and you fail to provide that Personal Information when requested, we may not be able to provide you with our products or services. We make sure we consider and balance any potential impact on you and your rights before we process your Personal Information. We do not use your Personal Information for activities where our interests are overridden by the impact on you unless we have your consent or are otherwise required or permitted to by law. In certain circumstances, we as a data processor on behalf of real estate agent partners, and, in those circumstances, we process your Personal Information for the purposes set out in this Policy consistent with the data processing terms of those partners.
 
We also may rely on your consent to collect, use or disclose your Personal Information. If we are relying on your consent to process your Personal Information, you have the right to withdraw your consent at any time by contacting us at the information below.
 
We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Information for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.
 
If you are located in the EU and have any complaints regarding our privacy practices as a data controller, you have the right to make a complaint at any time to your local Supervisory Authority. However, we would appreciate the chance to address your concerns before you approach your Supervisory Authority, so please contact us first at the information below.
 
Your Rights
 
Applicable European data privacy laws give certain visitors the right to access their personal information. Your right of access can be exercised in accordance with the European data privacy laws. If you would like to request a copy of your personal information being held by us or request that it be deleted, or to update and/or correct your personal information or request that we provide a copy to another data controller of your personal information that you have provided to us, please contact us as detailed in the “Contact Us” section below. We will need enough information to ascertain your identity as well as the nature of your request. We will aim to respond to your request within one (1) calendar month of receipt of the request. Where we were unable to do so within the calendar month, we will notify you of the soonest practicable time within which we can respond to your request (and within three (3) months from the date of your request).
 
There are certain exemptions and restrictions of these rights under the European data privacy laws that enable personal information to be retained, processed or withheld from access and we will inform you of these exemptions and restrictions, if applicable. If you would like to exercise any of these rights, please contact us as detailed in the “Contact Us” section below.
 
International Data Transfers
We offer European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our customers that operate in the European Union and the United Kingdom, and make transfers of Personal Information from those jurisdictions to the United States and other countries that lack adequacy determinations. Please contact us as detailed in the “Contact Us” section below for more information.
Personal Information Concerning Children
 
Our Website or App is not intended for anyone under the age of 16. We do not knowingly collect Personal Information on our Website or App from individuals under the age of 16, unless the Personal Information is submitted with verifiable parental consent. If you are under 16, please do not use or provide any information on our Website or App or provide any information about yourself to us, including your name, address, telephone number, e-mail address, or interests. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information as soon as possible. If you believe we might have any information from or about a child under 13, please contact us using the information below.

Updates to the Policy
We may update this Policy periodically as we offer new products and services, and as our business, technology, and laws change. You can determine when this Policy was last revised by referring to the “Last updated” noted below. Any changes will become effective upon posting of the revised Policy.
 
Contact Us
Openn North America Inc.
[support@openn.com]
1340 Reynolds Ave #116-1095, Irvine, CA 92614