GDPR Privacy Policy

Effective date: January 30th, 2023

Osa Commerce Inc, Osa Operations LLC, Osa Commerce IL, (“OSA COMMERCE INC  "us", "we", or "our") operates the OSA COMMERCE INC .com website (hereinafter referred to as the "Service").

This page informs you of our policies regarding the collection, use and disclosure of Personal Data (as defined below) when you use our Service and the choices you have associated with that data.

Please review this Privacy Policy carefully. By using the Service, you agree to the collection, use and disclosure of Personal Data in accordance with this Privacy Policy. If you do not agree with the privacy practices described in this Privacy Policy, you must exit the Service immediately.

Definitions

Service
Service is the OSA COMMERCE INC .com website operated by OSA COMMERCE INC .

Personal Data
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Data Controller
Data Controller means the natural or legal person who (either alone or jointly with other persons) determines the purposes for which and the manner in which any Personal Data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes Personal Data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your Personal Data more effectively.

Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain Personal Data, which Data may include:

  • Email address
  • First name and last name
  • Phone number
  • Street Address, State, Province, ZIP/Postal code, City

Usage Data

We may also collect Usage Data, which may include information such as your computer's IP address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

We collect Usage Data through the use of cookies and other data collection tools. For more information about these data collection tools, please see the section of this Privacy Policy titled “Cookies and Other Data Collection Tools.”

If we combine any Usage Data with Personal Data, we will treat the combined data as Personal Data in accordance with this Privacy Policy.

Cookies and Other Data Collection Tools

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other data collection tools are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.

Examples of cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

In addition to cookies, we use the analytics and behavioral remarketing tools described below.

Analytics

Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Behavioral Remarketing

OSA COMMERCE INC uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

Google Ads (AdWords)
Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Bing Ads Remarketing
Bing Ads remarketing service is provided by Microsoft Inc.

You can opt-out of Bing Ads interest-based ads by following their instructions: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

You can learn more about the privacy practices and policies of Microsoft by visiting their privacy policy page: https://privacy.microsoft.com/en-us/PrivacyStatement

Twitter
Twitter remarketing service is provided by Twitter Inc.

You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405

You can learn more about the privacy practices and policies of Twitter by visiting their privacy policy page: https://twitter.com/privacy

Facebook
Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

Pinterest
Pinterest remarketing service is provided by Pinterest Inc.

You can opt-out from Pinterest's interest-based ads by enabling the "Do Not Track" functionality of your web browser or by following Pinterest instructions: http://help.pinterest.com/en/articles/personalization-and-data

You can learn more about the privacy practices and policies of Pinterest by visiting their privacy policy page: https://about.pinterest.com/en/privacy-policy

AdRoll
AdRoll remarketing service is provided by Semantic Sugar, Inc.

You can opt-out of AdRoll remarketing by visiting this AdRoll Advertising Preferences web page: http://info.evidon.com/pub_info/573?v=1nt=1nw=false

For more information on the privacy practices of AdRoll, please visit the AdRoll Privacy Policy web page: http://www.adroll.com/about/privacy

Perfect Audience
Perfect Audience remarketing service is provided by NowSpots Inc.

You can opt-out of Perfect Audience remarketing by visiting these pages: Platform Opt-out (http://pixel.prfct.co/coo) and Partner Opt-out (http://ib.adnxs.com/optout).

For more information on the privacy practices of Perfect Audience, please visit the Perfect Audience Privacy Policy Opt-out web page: https://www.perfectaudience.com/privacy/index.html

 AppNexus

AppNexus remarketing service is provided by AppNexus Inc.

You can opt-out of AppNexus remarketing by visiting the Privacy the AppNexus Platform web page: http://www.appnexus.com/platform-policy#choicesFor more information on the privacy practices of AppNexus, please visit the AppNexus Platform Privacy Policy web page: http://www.appnexus.com/platform-policy/

We use cookies and the other data collection tools described above to track the activity on our Service. These tools help us improve the Service by providing us with data about which parts of the Service are most popular, enabling us to analyze technical and navigational data about the Service and helping us to detect and prevent fraud. We also use these tools to help improve your experience with the Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service. To find out more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org.

Use of Data

OSA COMMERCE INC uses the Personal Data that we collect as described at the point of collection or as follows:

  • To provide and maintain our Service.
  • To notify you about changes to our Service.
  • To allow you to participate in interactive features of our Service when you choose to do so.
  • To provide customer support.
  • To gather analysis or valuable information so that we can improve our Service.
  • To monitor the usage of our Service.
  • To detect, prevent and address technical issues and security issues.
  • To provide you with newsletters, marketing or promotional materials and other information that we think may be of interest to you, including to provide you with information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about.
  • To enforce and protect our rights and the rights of others.
  • For archival and backup purposes.

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), OSA COMMERCE INC legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

OSA COMMERCE INC may process your Personal Data because:

  • We need to perform a contract with you
  • You have given us permission to do so
  • The processing is in our legitimate interests and it is not overridden by your rights
  • For payment processing purposes
  • To comply with the law

Retention of Data

OSA COMMERCE INC will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

Transfer of Data

Your Personal Data may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside of the United States and choose to provide information to us, please note that we transfer the Personal Data to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of your Personal Data represents your agreement to that transfer.

OSA COMMERCE INC will take all the steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

We may share your Personal Data as described at the point of collection or as follows:

Business Transaction

If OSA COMMERCE INC is involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

Disclosure for Law Enforcement

Under certain circumstances, OSA COMMERCE INC may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

OSA COMMERCE INC may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation.
  • To protect and defend the rights or property of OSA COMMERCE INC .
  • To prevent or investigate possible wrongdoing in connection with the Service.
  • To protect the personal safety of users of the Service or the public.
  • To protect against legal liability.

Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used. Service Providers with whom we share your Personal Data include those third parties listed under the headings “Analytics” and “Behavioral Remarketing” above; we share your Personal Data with such Service Providers for the purposes described in those sections. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Payments

We may provide paid products and/or services within the Service. In that case, we use Service Providers for payment processing.

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your Personal Data is governed by their privacy policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are: Stripe

Their privacy policy can be viewed at https://stripe.com/us/privacy.

Other than as described above, we do not share your Personal Data with third parties, including with third parties for their marketing purposes.

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially reasonable security measures to protect your Personal Data, we cannot guarantee its absolute security, and we make no representations or warranties with respect to the sufficiency of those security measures nor will be responsible for any direct or indirect damages that you may incur as a result of a security breach or technical malfunction.

Do Not Track

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Additional Information for EU Visitors

With respect to “personal data” as defined by Regulation (EU) 2016/679 (“GDPR”) that you may provide to us through the Service, we serve as the “controller.”

As noted above, we provide the Service from servers located in the United States. If you are accessing the Site from the European Union, we will only transfer your personal information to the United States through the use of appropriate safeguards. We process personal information to pursue our legitimate business interest to operate the Site and as described in the section titled “Use of Data” above. To learn more about with whom we share your personal information please refer to the section titled “Disclosure of Data” above. To learn about our data retention practices, refer to the section titled “Retention of Data” above.

In certain circumstances, you have the following data protection rights:

The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personal Data.

The right of restriction. You have the right to request that we restrict the processing of your personal information.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any time where OSA COMMERCE INC relied on your consent to process your personal information.

If you wish to be informed about what Personal Data we hold about you and to exercise the rights described above, please contact us at the contact information set forth at the bottom of this Privacy Policy.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data.

Links to Other Websites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

Our Service is not directed toward or designed to attract and we do not knowingly collect Personal Data from anyone under the age of 18.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time without notice to you. We will post all changes to this Privacy Policy on the Service and they will become effective immediately upon being posted. Your continued use of the Service following the posting of changes to this Privacy Policy constitutes your acceptance of those changes. Therefore, you are advised to check the Effective Date of this Privacy Policy and review the “Notification of Material Changes to this Privacy Policy” section each time that you use the Service. Notwithstanding the foregoing, to the extent required by law, we will seek your consent to any material changes to this Privacy Policy.

Notification of Material Changes to This Privacy Policy

This section identifies material changes to this Privacy Policy since the Effective Date.

(None at present).

Contact Us

If you have any questions about this Privacy Policy, You can contact us: