GDPR | General Data Protection Regulation
GENERAL DATA PROTECTION REGULATION
Last updated June 1, 2019
Thank you for choosing to be part of our community at O2S.Group (hereinafter known as, ‘we’, ‘us’ or ‘our’). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy or our practices with regards to your personal information, please submit your message in writing to us using the contact information provided below.
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TABLE OF CONTENTS
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE USE YOUR INFORMATION?
- WILL YOUR INFORMATION BE SHARED WITH ANYONE?
- DO WE USE GOOGLE MAPS?
- HOW DO WE HANDLE YOUR SOCIAL LOGINS?
- WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- DO WE COLLECT INFORMATION FROM MINORS?
- WHAT ARE YOUR PRIVACY RIGHTS?
- DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
- DO WE MAKE UPDATES TO THIS POLICY?
- HOW CAN YOU CONTACT US ABOUT THIS POLICY?
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1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
We collect personal information that you provide to us such as name, address, contact information, passwords and security data, payment information, and social media login data.
We collect personal information that you voluntarily provide to us when registering at the Sites or Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites or Apps or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Sites or Apps, the choices you make and the products and features you use. The personal information we collect can include the following:
Name and Contact Data.
We collect your first and last name, email address, postal address, phone number, and other similar contact data.
We collect passwords, password hints, and similar security information used for authentication and account access.
We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.
Social Media Login Data.
We provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the Information described in the section called ‘HOW DO WE HANDLE YOUR SOCIAL LOGINS’ below.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Sites or Apps.
We automatically collect certain information when you visit, use or navigate the Sites or Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites or Apps and other technical information. This information is primarily needed to maintain the security and operation of our Sites or Apps, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies.
Information collected through our Apps
We may collect information regarding your geo-location, mobile device, push notifications, when you use our apps.
If you use our Apps, we may also collect the following information:
- Geo-Location Information.
We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
- Mobile Device Access.
We may request access or permission to certain features from your mobile device, including your mobile device’s calendar, microphone, camera, reminders, sensors, sms messages, social media accounts, contacts, bluetooth, storage, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
- Mobile Device Data.
We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
- Push Notifications.
We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
Information collected from other sources
We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.
We may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links).
2. HOW DO WE USE YOUR INFORMATION?
We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Sites or Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (‘Business Purposes’), in order to enter into or perform a contract with you (‘Contractual’), with your consent (‘Consent’), and/or for compliance with our legal obligations (‘Legal Reasons’). We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
- To facilitate account creation and logon process
With your Consent. If you choose to link your account with us to a third-party account *(such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process. See the section below headed ‘HOW DO WE HANDLE YOUR SOCIAL LOGINS’ for further information.
- To send you marketing and promotional communications
For Business Purposes. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the ‘WHAT ARE YOUR PRIVACY RIGHTS’ below).
- To send administrative information to you
For Business Purposes, Legal Reasons and/or possibly for Contractual. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
- Fulfill and manage your orders
For Contractual reasons. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Sites or Apps.
- To post testimonials
With your Consent. We post testimonials on our Sites or Apps that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at [email protected]* and be sure to include your name, testimonial location, and contact information.
- Deliver targeted advertising to you
For our Business Purposes. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
- Administer prize draws and competitions
For our Business Purposes. We may use your information to administer prize draws and competitions when you elect to participate in competitions.
- Request Feedback
For our Business Purposes. We may use your information to request feedback and to contact you about your use of our Sites or Apps.
- To protect our Sites
For Business Purposes. We may use your information as part of our efforts to keep our Sites or Apps safe and secure (for example, for fraud monitoring and prevention).
- To enable user-to-user communications
With your Consent. We may use your information in order to enable user-to-user communications with each user’s consent.
- To enforce our terms, conditions and policies
For Business Purposes, Legal Reasons and/or possibly Contractual.
- To respond to legal requests and prevent harm
For Legal Reasons. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- For other Business Purposes.
We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites or Apps, products, services, marketing and your experience.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.
We only share and disclose your information in the following situations:
- Compliance with Laws.
We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests and Legal Rights.
We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
- Vendors, Consultants and Other Third-Party Service Providers.
We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites or Apps, which will enable them to collect data about how you interact with the Sites or Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
- Business Transfers.
We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Third-Party Advertisers.
We may use third-party advertising companies to serve ads when you visit the Sites or Apps. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
- With your Consent.
We may disclose your personal information for any other purpose with your consent.
- Offer Wall.
Our Apps may display a third-party hosted ‘offer wall’. Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for acceptance and completion of an advertisement offer. Such an offer wall may appear in our mobile application and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will leave our mobile application. A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account.
5. DO WE USE GOOGLE MAPS AND/OR OTHER GOOGLE PRODUCTS?
Yes, we use Google Maps and/or other Google products for the purpose of providing better service.
By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service. By using our implementation of the Google Maps APIs, you agree to allow us to gain access to information about you including personally identifiable information (such as usernames) and non-personally identifiable information (such as location). We will be collecting the following information: Information provided by a user
For a full list of what we use information for, please see the previous section titled ‘HOW DO WE USE YOUR INFORMATION?’ and ‘WILL YOUR INFORMATION BE SHARED WITH ANYONE?’
You agree to allow us to obtain or cache your location. You may revoke your consent at any time. We use information about location in conjunction with data from other data providers.
The Maps APIs that we use store and access cookies and other information on your devices. If you are a user currently in the European Union, please take a look at our Terms/Conditions of Use and consent policy.
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
If you choose to register or log in to our websites using a social media account, we may have access to certain information about you.
Our Sites or Apps offer you the ability to register and login using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public.
7. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, the transmission of personal information to and from our Sites or Apps is at your own risk. You should only access the services within a secure environment.
10. DO WE COLLECT INFORMATION FROM MINORS?
We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites or Apps, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites or Apps. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at [email protected]*
11. WHAT ARE YOUR PRIVACY RIGHTS?
You may review, change, or terminate your account at any time.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
If you would at any time like to review or change the information in your account or terminate your account, you can:
> Log into your account settings and update your user account.
Cookies and similar technologies:
Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites or Apps. To opt-out of interest-based advertising by advertisers on our Sites or Apps visit http://www.aboutads.info/choices/
Opting out of email marketing:
You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:
> Note your preferences when you register an account with the site.
12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the ‘Shine The Light’ law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Sites or Apps, you have the right to request removal of unwanted data that you publicly post on the Sites or Apps.
To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Sites or Apps, but please be aware that the data may not be completely or comprehensively removed from our systems.
13. DO WE MAKE UPDATES TO THIS POLICY?
Yes, we will update this policy as necessary to stay compliant with relevant laws.
14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO):
Chief Legal & Compliance Officer, by email at: [email protected]*
If you have any further questions or comments about us or our policies, submit your message in writing to us at: [email protected]*
[*Note: Replace O2S with O2S.Group]