Optimal Market risk Management Advisors Inc. as “Optimal MRM”, “our”, “us”, “we”
www.optimalmrm.com and .ca shall be referred to as the “Site”
A visitor or end user of our Site is referred to as “you”, “your(s)” or “yourself”
Personally-Identifiable Information shall be referred to as “PI”
Terms and Conditions of Service shall be referred to as “Terms”
In addition, the terms “collect”, “process”, “treat”, “use”, “share”, “disclose”, “divulge” and analogous words shall refer to your PI and other data collected from our visitors and end users.
Introduction & General Scope
Existing and prospective client privacy is of paramount importance to Optimal MRM, which makes this Policy available throughout this Site in order to assist in the understanding of the handling of PI in the course of its use.
Unless otherwise stated to the contrary, this Policy applies to this Site, and any website that references this Policy, any of Optimal MRM’s operated websites and platforms, as well as any data we may collect across partnered and unaffiliated websites.
Optimal MRM provides, operates and manages a platform that offers an “Online Training Service”, which is offered to our users via a subscription-based model allowing them to access digitized versions of video recordings, downloadable portable document format files and excel spreadsheets, among other type of content.
Registration is required in order to access and/or subscribe to Optimal MRM’s Online Training Service. Our business model is in no way dependent on advertising, and hence, Optimal MRM has no interest whatsoever in sharing any registered user information with any third parties for any purpose.
The Optimal MRM team does every possible effort to keep your trust; and thus, we adhere to these general privacy principles, in order to defend your privacy:
- Optimal MRM does not rent or sell your PI.
- Optimal MRM does not divulge your contact information to third parties or other users without your consent.
- Any PI that you give to Optimal MRM will be protected by industry standard technology and codes of ethics.
User Agreement & Registration
For purposes of this Policy, the Site shall be the initial point of contact between you and Optimal MRM, and will serve as the point of collection of any personal data you may provide us.
As a user of our Site, you will be asked to create a profile with us, by clicking on the “I Agree” checkbox on the registration form or box or other similar means. Through that action, you thereby acknowledge and agree to the terms of this Policy, which is and constitutes a legal, binding agreement between you and Optimal MRM.
This Policy is freely available for your review prior to registration, and if you do not agree to its terms, your remedy shall consist of not registering into the Site, and exiting the web tab though which you visited us.
Accordingly, by registering with us or otherwise using our products and services, you consent to the collection, transfer, processing, storage, and disclosure of your PI as described in this Policy. If you do register, rest assured that any personal information you provide is strictly protected and forbidden from being shared with any unauthorized third-party organization.
As our user, you will normally be able to manage and select the quantity and type of PI you may reveal to us when using our Site, usually in your account settings. Registered users can edit their identifiable information within the Online Training Service’s Member’s Profile Page. If you no longer wish for Optimal MRM to possess your information, you may request in writing or by email, deletion of your information by contacting Optimal MRM at the coordinates provided at the end of this Policy.
Collection of Personal Information
As a general rule, we collect both “Non-Personal Information” and “Personal Information” from our users:
“Non-Personal Information” includes information that cannot be used to personally identify an individual person, such as anonymous usage data, general demographic information that we may collect, number of clicks, platform types, preferences you submit and preferences that are generated based on the data you submit.
We collect non-personally identifiable information via third party tools, such as aggregate user statistics, analytics, demographic information, and web site usage information. As our user, you will generally be able to control and select the amount and type of PI you may disclose to us.
“Personally Identifying Information” includes information that can be used to personally identify an individual person, such as personal email, email address, name, phone number, tax information and address.
Finally, you hereby represent and warrant to Optimal MRM that you have the necessary rights and authorizations required for the disclosure of any and all PI. If you open an account with us representing a legal entity, you also represent and warrant that you have the necessary power and authorization.
Voluntary User Disclosure
Registration information is primarily required for the purposes of applying taxes, where applicable, to subscription orders as a function of the subscriber’s place of residence.
Since registration is not required in order to access website content that is publicly available, users can visit our Site anonymously, and henceforth we will collect PI from them only if they voluntarily submit such information.
Please be reminded that this Site is intended to make forums, blogs or similar available to its registered users, and henceforth registration may be required to use these features, particularly if you wish to leave comments or links to articles. You can always refuse to supply your PI to Optimal MRM, though in that case it may prevent you from engaging in part or all of the Site related activities.
Accordingly, if you post comments on articles in the ‘perspective’ section of the Site, any PI you provide in those comments or articles may be read, collated and used by anyone viewing them. As such, Optimal MRM will not be responsible for PI you may elect to make available in your comments on these articles. All comments are subject to approval by Optimal MRM before they are posted.
As a general policy, Optimal MRM does not approve for publication, perspective article comments which contain personal information, though it cannot guarantee that its customer support team will be able or willing to moderate or delete such type of comments.
Purpose of PI Collection
We will store your PI for the purposes of managing your collaboration with other users and clients, improve your user experience, send newsletters and contact you about inquiries for our services. Overall, we use the collected PI to provide and improve our services. Accordingly, we will generally collect, use and disclose your PI to:
- Provide, operate, maintain, improve, and promote our platform and our products and services.
- Verify your e-mail address and send you account notices.
- Develop, research, process, safeguard and improve our services.
- Conduct business research, for lead generation, customer relationship management and surveys.
- Offer promotions, newsletters, send service-related announcements and contact you about inquiries for our products and services.
- Investigate and prevent fraudulent transactions, unauthorized access to our services, and other suspicious activities.
- Monitor and analyze trends, usage, and activities in connection with our products and services and for marketing or advertising purposes.
Optimal MRM will keep any collected PI only as long as it is necessary, with regard to the purpose of its processing. This means that PI collected and processed for marketing and commercial purposes will be stored for as long as you have an active account, and for at least six (6) months after your account has been deleted or deactivated.
If you do not wish to disclose any or part of your PI to us, you may still be able to use some of the functionalities of our Site, though we will not be able to guarantee that you will be able to enjoy them at their fullest if you elect not to disclose it to us.
Security of Collected Information
The security of your PI is important to us, and this is why we use commercially reasonable efforts to store and maintain your PI in a secure environment. We take technical, administrative, and physical security measures designed to protect the PI that you provide to us, implementing implemented procedures designed to limit the disclosure of your PI to only such staff who have a need to know and only as necessary to carry out the stated purposes we have communicated to you.
In certain areas, such as when you provide credit card or other payment information to us, the Site works to help protect the security of your credit card and other payment information during transmission by using industry standard Secure Sockets Layer (SSL) encryption technology.
You are also responsible for helping to protect the security of your PI. For instance, never give out your email account information or your password for the Service to third parties. However, please be aware that no method of electronic transmission and storage can ever be 100% secure. Therefore, as is the case with any organization, Optimal MRM cannot guarantee the absolute security of information which is transmitted and/or stored electronically. Please keep in mind that the Internet is an inherently insecure means of communications due to its open architecture.
We will retain your PI only for as long as it is reasonably necessary for our business purposes (e.g. as long as your account is active). We will also retain and use your PI for our compliance obligations, to resolve disputes among our users, and enforce our contracts with authorized third parties.
Third Party Tools and PI Processors
In order to provide our services, we use third-party platforms and tools, such as those provided by Amazon Web Services, among other providers. Please be aware that such platforms are governed by their own terms, policies and personal data collection practices and policies. Accordingly, by acknowledging your consent to this Policy, you are also acknowledging the applicable terms and conditions and personal data procedures of such third-party platforms. Upon the case of any discrepancy or conflict among this Policy and the terms of them, the terms of the latter entities will govern.
We will keep a list of any sub-processors that will be involved in the processing of your PI due to the provision of our service and will inform you of any intended material changes concerning the addition or replacement of sub-processors before such changes are effective, thereby giving you the opportunity to object to such changes.
Our Site uses industry standard analytics packages which gather limited information on visitors to the company’s website automatically, and stores this anonymous information in server log files. This information may include IP addresses, browser type, basic IP information, referring pages, operating system used and date/time stamps. This information does not identify individual users; it is used only for site administration, as well as for analysis of website use and trends.
Additionally, cookies may be used to provide easier and faster access to our features such as logins and/or repeat visits. Cookies are very small text files that are stored on personal computers for reference purposes. Optimal MRM does not link the information stored in cookies to any personally identifiable information you have submitted while on this website.
Both session ID cookies and persistent cookies are used. A session cookie expires when your browser is closed, and a persistent cookie may stay on your hard drive for an extended period. Session cookies make it easier for you to navigate websites; persistent cookies can perform such activities as storing your password for forums or blogs so you do not have to sign in every time you visit those areas, and/or may be used to enable Optimal MRM to track and target the interests of its users so as to enhance the overall experience of using our Site.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. If you wish so, you can easily disable cookies on your web browsing software by following the step-by-step guides located at www.allaboutcookies.org and at www.youronlinechoices.com.
You can learn more about how to opt-out by browsing Google’s opting-out and privacy pages located at www.google.com, or the Network Advertising Initiative website located at www.networkadvertising.org.
You must at least be eighteen (18) years of age or older in order to purchase our products and/or to use our services. In compliance with the Child Online Protection Act (COPA), Optimal MRM does not knowingly collect any kind of information from persons under the age of thirteen (13). If we learn or have reason to suspect that any user or that any client, project or customer data appertains persons under the age of thirteen (13), we will freeze and/or delete any PI under that user’s account, without prior notice and without responsibility.
Lawful Disclosure of Personal Information
We, or our affiliates, clients, contractors, licensors’ officers, agents and/or representatives, reserve the right to allow access to any of your PI when we think it is reasonably important or when you violate the terms mentioned in this policy. Hereafter, we will have the right to disclose any or all gathered PI and/or data, when the following circumstances arise: (i) if necessary under an applicable law; (ii) in reply to a legal demand or subpoena from an agency of the law ; (iii) to protect ourselves and our affiliates from any legal third party claims and procedures that may be brought to us (inclusive of takedown notices); and/or (iv) to prevent or cause cessation of any undertakings that may be construed by us as having the ability to be or cause a predicament or hazard to us.
Disclosures to Business Successors
If our business is sold or merges in whole or in part with another business that would become responsible for providing the Site to you, we retain the right to transfer your PI to the new business. The new business would retain the right to use your PI according to the terms of this Policy as well as to any changes to this privacy notice as instituted by the new business.
We will also retain the right to transfer your PI if our company files for bankruptcy and some or all of our assets are sold to another individual or business.
Occasionally, we will ask you for express permission and approval to receive commercial communications in electronic format which are then sent to an electronic address and that contains a message asking recipients to participate in commercial activities such as newsletters, purchase of products, services and invitations to participate in surveys. We may also ask you to provide your mobile phone number so we can contact you about possible business opportunities, as well as to provide customer support.
If you no longer wish to receive email update and other commercial communications and messages, you may opt-out of receiving them by following the instructions included in each update or communication.
We will also send you service-related announcements on occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, or a new enhancement is released, which will affect the way you use our services, we might send you an email. Generally, you may not opt-out of these communications, which are neither commercial nor promotional in nature.
Third Party Links
Our Site may present our commercial partner’s hyperlinks as well as those of other third parties (e.g. under the ‘perspective’ section). Please be aware of this when you click on any such links; Optimal MRM is not responsible for the privacy practices and/or policies of any website other than OptimalMRM.com.
Notice to California Residents
In compliance with the California Civil Code Section 1798.83, residents of California are hereby notified that the websites referred to in this Policy and the appertaining personal information are respectively operated and safeguarded by Optimal Market risk Management Advisors Inc.
Users can obtain certain information about the personal information we may have access to, including disclosure thereof with third parties for direct marketing purposes (e.g. names and addresses of those third parties, types of services or products marketed thereby). If you wish to request a copy of your information disclosure, please contact us at by email as indicated in our contact page.
California Online Privacy Protection Act
In compliance with CalOPPA, we have hereby posted this conspicuous Policy to the public, indicating the PI being collected and the manner in which it may be disclosed and with whom. Accordingly, our users can may visit our platform using anonymous browsing, read this Policy linked from our home page, with the link including the word ‘Privacy’ or similar. We also comply with Policy changes notification to our users, and provide mechanisms that allow our users to manage their personal information.
GDPR Notice and your Rights as Data Subject
For the purposes of the GDPR, in the European Union, Optimal MRM is a “data controller” of the PI you provide to us for the primary purposes of providing you with our services.
The section below covers the certain situations that you, as data subject, and we as a data controller, are most likely to see, but you should also carefully review the full list of data subject rights here: https://gdpr-info.eu/chapter-3/. You retain the right to access, amend, correct or delete your PI where it is inaccurate at any time. Please contact us to do so.
- Right to be Forgotten: You can request us to be “forgotten”; that is, to have your entire PI removed from our service. If we are asked to do this, we will remove any PI you we collected from you as requester. We will also need to contact any third parties that process your PI on our behalf, such as our cloud service providers. To ensure that any personal data in Optimal MRM’ possession can be removed in a timely manner, you can relay any request to be “forgotten” to us by submitting a request-
- Right to Data Portability: Under the GDPR, our users located in the EU may request Optimal MRM to send them any PI in our possession. In this case, we will provide you with any PI that you have in a commonly used, machine-readable format.
- Right to Data Access: As a data subject, you can ask Optimal MRM to confirm how and where your PI is being stored and processed. You also have the right to know how such that data is shared with third parties by us.
- Right to Data Rectification: As data subject, you have the right to obtain from Optimal MRM, without undue delay, the rectification of inaccurate PI concerning you.
- Right to be Informed: You have the right to be informed about the PI we collect from you, and how we process it.
- Right to Object: You have the right to object to us processing your PI for the following reasons:
- Processing was not based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
- Direct marketing (including profiling);
- Processing for purposes of scientific/historical research and statistics; and
- Rights in relation to automated decision-making and profiling.
- Automated Individual Decision-Making and Profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
- Right to Complain: You have the right to file a complaint with supervisory authorities if your information has not been processed in compliance with the GDPR. If the supervisory authorities fail to address your complaint properly, you may have the right to a judicial remedy.
Your privacy request must include, at the least, the following information: (i) your complete name, address and/or e-mail address in order for us to notify you the response to your request; (ii) attached documents establishing your identity; and (iii) a clear and concise description of the PI with regard to which you seek to enforce any of your privacy rights. If you request rectification, please indicate amendments to be made and attach documentation to back up your request.
Upon receipt of your privacy request, and after due review, we may then edit, deactivate and/or delete your PI from our services within thirty (30) days. In case of secure databases under our control where deletion is impossible, we will make such information permanently inaccessible.
From time to time, this Policy may be translated into other languages for your convenience. The English language version of each of these documents shall be the version that prevails and governs your use of Site and our products and services. Upon the case of any conflict between the English language version and any translated version, the English language version will prevail.
Amendments to this Policy
Periodically, and at the final discretion of ourselves, we may update, change, suspend and/modify or our Site, our services, this Policy and/or our Terms, in whole or in part. We hereby reserve such right in order to operate our business and protect ourselves. Your use after any changes indicate your acceptance thereof and we will post a notice regarding such changes on our Site, and may also write an email to you or otherwise notify you.
Please contact us if you have any questions or concerns regarding this Policy.
This Policy was last updated on April 4, 2020.