Privacy Policy

1. Introduction

OpenAssets, Inc. ("the Company," "we," "us," or "our") operates openassetsx.com and the OpenAssets platform (collectively, the "Service"). OpenAssets provides AI-powered asset-data and compliance infrastructure for financial institutions: we ingest ownership records from custodian data feeds, normalize them to a canonical schema, and produce compliance-ready reconciliation output mapped to institutional regulatory requirements including SEC Rule 17a-4, GLBA, and CFTC Regulation 1.31.

This Privacy Policy explains what information we collect through the Service, how we use it, who we share it with, and the choices available to you. It applies to information collected through openassetsx.com and through direct communications with us.

The Company is based at 17 State Street, 27th Floor, New York, NY 10004 and can be reached at [email protected].

2. Information We Collect

2.1 Information You Provide

We collect information you submit directly, including:

• Contact details (name, email, phone) when you fill out a form, request early access, or reach out directly;
• Company information you choose to share (employer, role, custody structure, reconciliation workflow context);
• The content of any messages you send us.

When financial institutions engage with us for platform access, the information submitted in that process may include details about their back-office operations and data infrastructure. We handle such information under the confidentiality terms applicable to that relationship.

2.2 Information Collected Automatically

When you visit openassetsx.com, we automatically collect limited technical information:

• IP address and approximate location (city and region level);
• Browser type, operating system, device class;
• Pages visited, referring URLs, time on page;
• Cookie and similar identifiers (see Section 5).

This technical data is used solely to operate and improve the site. We do not build individual behavioral profiles for advertising purposes.

2.3 We Do Not Knowingly Collect Children's Data

openassetsx.com is a B2B institutional platform directed exclusively at financial professionals. It is not directed to children under 13. We do not knowingly collect personal information from children. If you believe a child has provided us information, contact [email protected] and we will delete it.

3. How We Use Information

OpenAssets is a compliance infrastructure company, and we treat data handling as a design discipline, not an afterthought. We use the information we collect to:

• Respond to early-access applications, product inquiries, and support requests;
• Operate, maintain, and improve the Service, including the reconciliation engine and compliance reporting modules;
• Send product updates and, with your consent where required, communications about OpenAssets developments relevant to RWA data management and compliance;
• Detect, investigate, and prevent fraud or unauthorized access;
• Comply with our legal obligations under applicable US federal and New York law, including financial-sector regulations that govern our institutional clients' obligations.

We do not sell personal information for monetary value. Where applicable state law treats certain advertising arrangements as a "sale" or "share," see your state's section below.

4. Sharing of Information

We share personal information only with:

• Service providers acting on our behalf (hosting infrastructure, email delivery, analytics) under contractual confidentiality terms that restrict their use to the services they perform for us;
• Authorities, when required by law or to protect rights, safety, or property, including in response to regulatory inquiries relevant to our financial-sector operations;
• A successor entity in the event of a merger, acquisition, or asset sale, subject to this Policy.

We do not sell personal information to third parties.

5. Cookies and Tracking

We use cookies and similar technologies to operate the site, remember preferences, and measure usage. For details and choices, see our Cookie Policy.

6. Data Retention

We retain personal information only as long as needed for the purposes described in this Policy, to satisfy legal or accounting obligations, and to resolve disputes. Specifically:

• Inactive marketing-list contacts are purged after 24 months;
• Server access logs are retained 90 days, then aggregated into anonymous statistics;
• Records associated with an active customer or partner relationship are retained for the life of that relationship plus such additional period as applicable law or our contractual obligations require.

Because OpenAssets serves financial institutions subject to SEC Rule 17a-4, GLBA, and related recordkeeping requirements, our clients retain responsibility for their own regulatory recordkeeping obligations. Our retention practices above apply to information we hold in our capacity as a service provider, not to the ownership and compliance records our clients produce through the platform.

7. Security

We use administrative, technical, and physical safeguards designed to protect personal information, including TLS encryption in transit, restricted-access databases, role-based access controls, and full audit logging. Our institutional clients receive additional contractual security terms appropriate to their regulatory environment. No system is perfectly secure; we cannot guarantee absolute security.

8. Your General Rights

Depending on your jurisdiction, you may have rights including access, correction, deletion, and the ability to limit certain processing. To make a request, email [email protected]. We will respond within the timeframe required by applicable law.

9. New York Residents

New York does not currently have a comprehensive consumer privacy statute. As a matter of policy, the Company extends the following baseline rights to all U.S. residents regardless of state of residence.

9.1 Baseline Rights

• Right to Know: request the categories of personal information we have collected about you.
• Right to Delete: request deletion of personal information you have provided.
• Right to Correct: request correction of inaccurate personal information.
• Right to Opt Out of Marketing: unsubscribe from marketing emails or opt out via the link in each marketing message.

9.2 How to Exercise

Email [email protected] with a description of your request and enough detail for us to verify your identity. We respond within 45 days.

9.3 Sector-Specific Rights

Because OpenAssets serves financial institutions, visitors who are protected by federal sector laws including GLBA may have additional rights with respect to data covered by those statutes. OpenAssets clients who are financial institutions subject to GLBA remain responsible for their own compliance with GLBA's customer notice and safeguard requirements.

9.4 California Visitors

If you are a California resident, you may also exercise the rights granted under the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA"), including the right to know, the right to delete, the right to correct, and the right to opt out of sale or sharing. The Company does not sell personal information and does not "share" personal information for cross-context behavioral advertising.

To submit a CCPA / CPRA request, email [email protected] with the subject line "California Privacy Request."

10. Changes to This Policy

We may update this Policy from time to time. Material changes will be reflected by a new "Last updated" date and, where appropriate, a notice on the Service.

11. Contact

Questions, requests, or complaints can be sent to: