Privacy Policy
Last modified: October 9, 2023
1. Introduction
Operato LLC (“Operato”) respects your privacy and is committed to protecting it through Operato’s compliance with this Operato Privacy Policy (the “Policy” or “Privacy Policy”).
This Policy describes the types of information Operato may collect from you or that you may provide when you visit or use, whether as a guest or a registered use www.OperatoAdvisory.com and any other Operato website or client portal related to Operato (collectively, the “Websites”), any Operato mobile or desktop apps (the “Apps”), and any content, functionality, technology solutions and services offered on or through the Websites or Apps (collectively, the “Services”), and Operato’s practices for collecting, using, maintaining, protecting, and disclosing that information. The Website, Apps and Services are collectively referred to as the “Platform.” Capitalized terms not defined in this Privacy Policy shall have the meanings attributed to them in the Operato Platform Terms of Use located at https://www.operatoadvisory.com/platform-terms-of-use.
This Policy applies to information Operato collects:
● On the Platform.
● In email, text, and other electronic messages, contacts, or calls between you, Operato, and/or the Platform.
● When you interact with Operato’s advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy.
● Through the provision of Operato Services.
It does not apply to information collected by any third party that gets access to the information, including through any application or content (including advertising) that may link to or be accessible from, on or through the Platform or any information you provide to or is collected by any third party, including any organizations.
Please read this Policy carefully to understand Operato’s policies and practices regarding your information and how Operato will treat it. If you do not agree with this Policy, your choice is not to use the Platform or Operato’s Services. By accessing or using this Platform you agree to this Privacy Policy. This Policy may change from time to time (see Changes to the Operato Privacy Policy below). Your continued use of the Platform and after Operato makes changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.
2. Children Under the Age of 16
The Platform is not intended for individuals under 16 years of age. No one under age 16 may provide any information to or on the Platform. Operato does not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on the Platform, or through any of its features, register on the Platform, or provide any information about yourself to Operato, including your name, address, telephone number, email address, or any screen name or username you may use. If Operato learns that it has collected or received personal information from a child under 16 without verification of parental consent, Operato will delete that information. If you believe Operato might have any information from or about a child under 16, please contact us by sending an email to cancel@operatoadvisory.com.
California residents under 18 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights section below for more information.
3. Information Operato Collects About You and How Operato Collects It
Operato collects several types of information from and about users of the Platform:
● Directly from you when you provide it to Operato, including as part of the Services.
● Automatically when you visit or use any portions of the Platform.
Information You Provide to Operato
When you register with or use the Platform, including the Services, Operato may ask that you provide information:
● By which you may be personally identified, such as name, postal address, e-mail address, telephone number, employer, job title or position, compensation information, online profile (such as LinkedIn, Facebook, etc.), or other identifier by which you may be contacted online or offline (“personal information”).
● That is about you but individually does not identify you.
The information Operato collects on or through the Platform, including the Services, may include:
● Information that you provide by filling in forms on the Platform. This includes information provided at the time of registering to use the Platform, subscribing to any service, posting material, and requesting further services. Operato may also ask you for information when you enter a promotion sponsored by Operato, and when you report a problem with the Platform.
● Records and copies of your correspondence (including email addresses and phone numbers) if you contact Operato.
● Your responses to surveys that we might ask you to complete for research purposes.
● Details of transactions you carry out through the Platform.
● Your search queries on the Platform.
● Information you provide to Operato as part of the Services.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Platform or transmitted to other users of the Platform or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, Operato cannot control the actions of other users of the Platform with whom you may choose to share your User Contributions. Therefore, Operato cannot and does not guarantee that your User Contributions will not be viewed by unauthorized persons.
Information Operato Collects Through Automatic Data Collection Technologies
When you access, use, navigate through and interact with portions of the Platform, Operato may use technology to automatically collect:
● Usage Details. When you access and use the Platform, Operato may automatically collect certain details of your access to and use of the Platform, including location data, logs, and other communication data and the resources that you access and use on or through the Platform.
● Device Information. Operato may collect information about your mobile device, computer and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
If you do not want Operato to collect this information do not visit or use the Platform.
The technologies Operato uses for this automatic data collection may include:
● Cookies (or mobile/browser cookies). A cookie is a small file placed on the hard drive of your computer or other device. You may be able to refuse to accept mobile or browser cookies by activating the appropriate setting on your device or browser. However, if you select this setting, you may be unable to access certain parts of the Platform. Unless you have adjusted your browser setting so that it will refuse cookies, Operato’s system will issue cookies when you direct your browser to the Platform.
● Web Beacons. Pages of the pay Platform and Operato’s e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Operato, for example, to count users who have visited those pages or opened an email and for other related app or platform statistics (for example, recording the popularity of certain content and verifying system and server integrity).
● Local Storage Objects. Operato may elect to use Local Storage Objects (LSOs) such as HTML5 to store blog user preferences and information such as email address.
Operato does not collect personal information automatically, but Operato may tie this information to personal information about you that Operato collects from other sources or that you provide to Operato.
4. Third-Party Use of Cookies and Other Tracking Technologies
When you use the Platform, or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:
● Advertisers, ad networks, and ad servers.
● Analytics companies.
● Your mobile device manufacturer.
The applicable payment processor, including credit card companies, WIX Payments, Stripe, PayPal, Apple Pay, etc.
Operato may also partner with other third parties to either display advertising on the Platform or to manage Operato’s advertising on other websites. Operato’s third-party partners may use technologies such as cookies to gather information about your activities on the Platform in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for interest-based ads, you may opt-out by sending an email to opt-out@operatoadvisory.com. Please note this does not opt you out of being served ads. You will continue to receive generic ads.
These third parties may use tracking technologies to collect information about you when you use the Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different platforms, apps, and other online services platforms. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
Operato does not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see below.
Below are some of the third-party providers that may be used and links to their privacy policies:
● Zoom. Operato uses Zoom for communications between Operato and Clients. Zoom privacy policy is located at https://explore.zoom.us/en/privacy/.
● Notion. Operato uses Notion to store notes from the provision of Services. Notion’s privacy policy is located at https://www.notion.so/Privacy-Policy-3468d120cf614d4c9014c09f6adc9091.
● WIX Payments. Operato works with WIX payments to process payment. By accessing or using the Platform, You expressly agree to and grant WIX Payments the right to use Your personal information in accordance with the WIX.com Privacy Policy, https://www.wix.com/about/privacy
5. How Operato Uses Your Information
Operato uses information that Operato collects about you or that you provide to Operato, including any personal information:
● To provide you with the Platform, and its contents, and any other information, products or Services that you request from Operato.
● For analytics purposes related to compensation programs and trends.
● To fulfill any other purpose for which you provide it.
● To carry out Operato’s obligations and enforce Operato’s rights arising from any contracts entered into between you and Operato, including for billing and collection.
● To notify you about changes to the Platform or any products or Services Operato offers or provides though it.
● To allow you to participate in interactive features on the Platform.
● To understand and set your communication preferences.
● In any other way Operato may describe when you provide the information.
● For any other purpose with your consent.
The information Operato collects helps Operato to improve the Platform and to deliver a better and more personalized service, including by enabling Operato to:
● Estimate Operato’s audience size and usage patterns.
● Store information about your preferences, allowing Operato to customize the Platform according to your individual interests.
● Speed up your searches.
● Recognize you when you return to the Platform.
Operato may also use your information to contact you about Operato’s own and third parties’ goods and services that may be of interest to you. If you do not want Operato to use your information in this way, please send an email to Operato at opt-out@operatoadvisory.com. For more information, see below.
Operato may use the information it has collected from you to enable Operato to display advertisements to Operato’s advertisers’ target audiences. Even though Operato does not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
6. Disclosure of Your Information
Operato may share Your personal information with service providers that perform services for Operato that are necessary for the orderly operation of the Platform, such as providing marketing assistance, analyzing User Content, and processing payment card information Personal information handled by these service providers is subject to their terms and privacy policies. Please review the service provider’s terms and privacy policies to better understand how they manage your data.
Operato may also disclose personal information that Operato collects, or you provide, as described in this Privacy Policy:
● To Operato’s subsidiaries and affiliates.
● To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Operato’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Operato about Platform users is among the assets transferred.
● To third parties to market their products or services to you if you have not opted out of these disclosures. For more information, see Choices About How Operato Uses and Discloses Your Information below.
● To fulfill the purpose for which you provide it. For example, if you give Operato an email address to use the “email a friend” feature of the Platform, Operato will transmit the contents of that email and your email address to the recipients.
● For any other purpose disclosed by Operato when you provide the information.
● With your consent.
● To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
● To enforce or apply the Platform Terms of Use at https://www.operatoadvisory.com/platform-terms-of-use, the Terms of Service at https://www.operatoadvisory.com/terms-of-service, and other agreements, including for billing and collection purposes.
● If Operato believes disclosure is necessary or appropriate to protect the rights, property, or safety of Operato, Operato’s customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
7. Choices About How Operato Uses and Discloses Your Information
Operato strives to provide you with choices regarding the personal information you provide to Operato. This section describes mechanisms Operato provides for you to control certain uses and disclosures of your information:
● Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, or block use of other tracking technologies, some parts of the Platform may then be inaccessible or not function properly.
● Location Information. You can choose whether or not to allow the Platform to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the Platform may become inaccessible or not function properly.
● Promotion by Operato. If you do not want Operato to use your email address or other contact information to promote Operato’s own or third parties’ products or services, you can opt-out by sending an email stating your request to opt-out@operatoadvisory.com
● Targeted Advertising by Operato. If you do not want Operato to use information that we collect or that you provide to Operato to deliver advertisements according to Operato’s advertisers’ target-audience preferences, you can opt-out by sending Operato an email stating your request to opt-out@operatoadvisory.com
● Disclosure of Your Information for Third-Party Advertising and Marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by sending us an email stating your request to opt-out@operatoadvisory.com
Operato does not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads or cookies from members of the Network Advertising Initiative (“NAI”) on the NAI’s opt out page http://www.networkadvertising.org/choices/ or the Digital Advertising Alliance website (http://www.aboutads.info/choices/), or if you are in the EU, the EDAA (http://www.youronlinechoices.eu/).
California residents may have additional personal information rights and choices. Please see below for more information.
8. Accessing and Correcting Your Information
You can review and change your personal information by logging into the Platform and visiting your account profile page, if applicable.
You may also send Operato an email at members@operatoadvisory.com to request access to, correct or delete any personal information that you have provided to Operato. Operato cannot delete your personal information except by also deleting your user account. Operato may not accommodate a request to change information if Operato believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you delete your User Contributions from the Platform, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Platform users. Proper access and use of information provided on the Platform, including User Contributions, is governed by the Platform Terms of Use located at https://www.operatoadvisory.com/platform-terms-of-use.
California residents may have additional personal information rights and choices. Please below for more information.
9. Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding Operato’s use of your personal information.
California’s “Shine the Light” law (Civil Code Section § 1798.83) may permit users of the Platform that are California residents to request certain information regarding Operato’s disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to California@operatoadvisory.com.
10. Rights of Residents in the European Union (EU)
If you use the Platform and reside in the EU, you are entitled by law to access, correct, amend, or delete personal information about you that we hold. A list of these rights is below. Please note that these rights are not absolute and certain exemptions apply. To exercise these rights please contact Operato at support. For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. In the event that we refuse a request under rights of access, we will provide you a reason as to why.
● The right to access: You have the right to ask Operato for copies of your personal information. This right has some exemptions, which means you may not always receive all the information we process. When making a request, please provide an accurate description of the data you want access to.
● The right to rectification: You have the right to ask Operato to rectify information you think is inaccurate. You also have the right to ask Operato to complete information you think is incomplete.
● The right to erasure: You have the right to ask Operato to erase your personal information in certain circumstances, including (i) when your personal information is no longer necessary for the purposes for which it was collected or processed or (ii) your information must be erased to comply with a legal obligation in EU Union or Member State law.
● The right to restrict processing: You have the right to ask Operato to restrict the processing of your information in certain circumstances, including (i) when the accuracy of the information is brought into question or (ii) when we no longer need the information for purposes of the processing but you require such information for the establishment, exercise, or defense of a legal claim. See “choices about your information” for some ways you can restrict processing.
● The right to object to processing: You have the right to object to processing if we are able to process your information because the process is in Operato’s legitimate interests. See “choices about your information” for some ways you can object to processing.
● The right to data portability: This only applies to information you have given Operato. You have the right to ask that we transfer the information you gave Operato from one organization to another, or give it to you.
● The right to lodge a complaint with the supervisory authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
11. How Long Do We Keep Your Information
Unless otherwise requested in writing, Operato will retain your personal information until the later of (i) the information is no longer necessary to accomplish the purpose for which it was provided; or (ii) one (1) year after your account with Operato is terminated.
We retain your information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations and/or as necessary to protect Operato’s legal rights or for certain business requirements. For example, when we process your payments, we will retain this data for longer periods of time as required for tax or accounting purposes. More specifically, we would retain some data for longer periods of time for the following reasons:
● Security, fraud, and abuse prevention: i.e. to protect you, other people, and Operato from fraud, abuse, and unauthorized access.
● Financial recordkeeping: When you make a payment to Operato we are often required to retain this information for long period of time for purposes of accounting, dispute resolution, and compliance with tax, anti-money laundering, and other financial regulations.
● Complying with legal or regulatory requirements: To meet any applicable law, regulation, legal process, or enforceable governmental request, as required to enforce Operato’s terms of service, including investigation of potential violations.
● Direct communications with Operato: If you have directly communicated with Operato, through a support channel, feedback form, or a bug report, we may retain reasonable records of those communications.
Even if you delete your account, keep in mind that the deletion by Operato’s third-party providers may not be immediate and that the deleted information may persist in backup copies for a reasonable period of time. For any privacy or data-protection-related questions, please write to privacy@operatoadvisory.com.
12. Data Security
Operato has implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where Operato has given you (or where you have chosen) a password for access to certain parts of the Platform, you are responsible for keeping this password confidential. Operato asks that you not share your password with anyone. Operato urges you to be careful about giving out information in public areas of the Platform or the sharing of information with third parties.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although Operato takes reasonable steps to protect your personal information, Operato cannot guarantee the security of your personal information transmitted to or through the Platform. Any transmission of personal information is at your own risk. Operato is not responsible for circumvention of any privacy settings or security measures contained on the Platform.
13. Changes to Operato’s Privacy Policy
Operato may update the Privacy Policy from time to time. If Operato makes material changes to how it treats its users’ personal information, Operato will post the new Privacy Policy on this page with a notice that the privacy policy has been updated. The date the Privacy Policy was last revised is identified at the top of the page.
14. Contact Information
To ask questions or comment about this Privacy Policy and Operato’s privacy practices, contact Operato at: privacy@operatoadvisory.com