ONOSYS PRIVACY POLICY

Last updated December 31, 2019
Last Reviewed December 31, 2019

Thank you for choosing to be part of our community at nuOnosys, Inc., doing business as Onosys (“Onosys”, “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 contact us at privacy@onosys.com.

When you visit our websites, including https://www.onosys.com, our mobile applications, and use our services, you trust us with your Personal Information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Sites or Apps and our services.

This privacy policy applies to all information collected through any of our websites, mobile applications, ("Apps"), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the "Sites").

Please read this privacy policy carefully as it will help you make informed decisions about sharing your Personal Information with us.

TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE USE YOUR INFORMATION?
  3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
  4. WHO WILL YOUR INFORMATION BE SHARED WITH?
  5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  6. DO WE USE GOOGLE MAPS?
  7. HOW LONG DO WE KEEP YOUR INFORMATION?
  8. HOW DO WE KEEP YOUR INFORMATION SAFE?
  9. DO WE COLLECT INFORMATION FROM MINORS?
  10. WHAT ARE YOUR PRIVACY RIGHTS?
  11. CONTROLS FOR DO-NOT-TRACK FEATURES
  12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  13. DO WE MAKE UPDATES TO THIS POLICY?
  14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

1. WHAT INFORMATION DO WE COLLECT?

Personal Information you disclose to us

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device (“Personal Information”). Personal Information does not include: (i) publicly available information from government records; (ii) deidentified or aggregate information; and (iii) certain other Personal Information protected by other sector-specific state or federal laws.

We collect the 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:

Personal Information. We collect your first and last name, email address, postal address, phone number, gender, birth date, and other similar information and contact data.

Customer Account Information. When you register and create an account on our Sites or Apps, we collect your first and last name, email address, password, and any other security information used to authenticate and access your account. In addition, we collect information about how you configure your account and the services used. We refer to all that information collectively as “Customer Account Information.” Customer Account Information is required to identify you as a customer and permit you to access your account(s). By voluntarily providing us with your Customer Account Information, you represent that you are the owner of such personal data or otherwise have the requisite consent to provide it to us.

Commercial Information. We collect records of products or services purchased, obtained, or considered or other purchasing or consuming histories or tendencies.

Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), billing address, and the security code associated with your payment instrument. The number provided from credit cards and gift cards is encrypted in compliance with the Payment Card Industry Data Security Standard.

Information automatically collected

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

If you use our Apps, we may also collect your 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.

Information collected from other sources

We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: social media profile information; marketing leads and search results and links, including paid listings (such as sponsored links).

2. HOW DO WE USE YOUR INFORMATION?

Onosys only processes Personal Information in a way that is compatible with and relevant to the purpose for which it was collected or authorized. As a general matter, for all categories of data described above, we may use the information (including Personal Information, to the extent applicable) to:

  • To facilitate account creation and logon process. 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.
  • Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, credits, and refunds made through the Sites or Apps.
  • Request Feedback. We may use your information to request feedback and to contact you about your use of our Sites or Apps.
  • For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends and to evaluate and improve our Sites or Apps, products, services, marketing and your experience. We may also use your Personal Information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Sites and Apps is among the assets transferred.
  • To Enable Access. We may use your information in order to provide you with our Services and enable you to access and use our Sites and Apps. This also may include personalizing the Sites and Apps, including by providing features or content that matches your preferences.
  • Comply with Legal Obligations. We may use your information to comply with legal obligations as well as to investigate and prevent fraudulent transactions, unauthorized access to our Services, and other illegal activities.

We will not collect additional categories of Personal Information or use the Personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We may disclose your Personal Information to a third-party for a business. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. We may process or share data based on the following legal basis:

  • Consent: We may process your data if you have given us specific consent to use your Personal Information in a specific purpose.
  • Legitimate Interests: We may process your Personal Information when it is reasonably necessary to achieve our legitimate business interests.
  • Performance of a Contract: Where we have entered into a contract with you or have agreed to provide you with our services, we may process your Personal Information to fulfill the terms of our contract or provision of services.
  • Legal Obligations: We may disclose your Personal 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: We may disclose your Personal 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.

More specifically, we may need to process your data or share your Personal Information in the following situations:

  • Vendors, Consultants and Other Third-Party Service Providers. We may share your Personal Information 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.
  • Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.

4. WHO WILL YOUR INFORMATION BE SHARED WITH?

In the preceding twelve (12) months, Onosys has disclosed the following categories of Personal Information for a business purpose:

  • Identifiers
  • Commercial information
  • Internet or other similar network activity
  • Inferences drawn from other Personal Information.

We disclose your Personal Information for a business purpose to the following third parties:

  • Content Optimization
    - Google Fonts
  • Functionality and Infrastructure Optimization
    - Microsoft Azure
  • Web and Mobile Analytics
    - Google Analytics and Google Tag Manager
  • App Testing
    - Google Play Console and TestFlight

We have categorized each party so that you may easily understand the purpose of our data collection and processing practices.

In the preceding twelve (12) months, Onosys has not sold Personal Information.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: privacy@onosys.com or Compliance Department, Onosys, 5005 Rockside Road, Suite 1100, Independence, OH 44131, United States. However, please know we do not currently sell data triggering that statute's opt-out requirements.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

6. DO WE USE GOOGLE MAPS?

Our Sites and Apps use Google Maps Platform. You may find the Google Maps Platform Terms of Service here. To better understand Google’s Privacy Policy, please refer to this link.

By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service. You agree to allow us to obtain or cache your location.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

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, 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.

9. DO WE COLLECT INFORMATION FROM MINORS?

Our Sites, Apps and website are not intended for children under 13 years of age. We do not knowingly solicit Personal Information from or market to children under 13 years of age. If you are under the age of 13, please do not use our Sites or Apps or send information about yourself to us. By using the Sites or Apps, you represent that you are at least 13 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 13 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 13, please email us at privacy@onosys.com or write to us at Compliance Department, Onosys, 5005 Rockside Road, Suite 1100, Independence, OH 44131, United States.

10. WHAT ARE YOUR PRIVACY RIGHTS?

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Contact us using the contact information provided.
  • Log into your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

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.

Opting out of email marketing: Onosys does not send marketing emails, however, companies that provide services through Onosys’ Sites and Apps may send marketing materials. To unsubscribe to such marketing, please contact the company directly. However, after you have opted out of marketing, Onosys 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.
  • Access your account settings and update preferences.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not- Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

The California Consumer Privacy Act (“CCPA”) provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of Personal Information we collected about you.
  • The categories of sources for the Personal Information we collected about you.
  • Our business or commercial purpose for collecting or selling that Personal Information.
  • The categories of third parties with whom we share that Personal Information.
  • The specific pieces of Personal Information we collected about you (also called a data portability request).
  • If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
    Sales, identifying the Personal Information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Emailing us at privacy@onosys.com.
  • Sending a written request to us at:
    Compliance Department
    Onosys
    5005 Rockside Road, Suite 1100
    Independence, OH 44131
    United States

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12- month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, which may include:
    - Your account username
    - Other specific information about your account
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to [45/90] days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

Onosys does not sell consumer information.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

California's "Shine the Light" Law

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Sites and Apps that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@onosys.com or write us at Compliance Department, Onosys, 5005 Rockside Road, Suite 1100, Independence, OH 44131, United States.

13. DO WE MAKE UPDATES TO THIS POLICY?

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information. Your continued use of our Sites and Apps following the posting of changes constitutes your acceptance of such changes.

14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may contact our Compliance Department by email at privacy@onosys.com, or by post to:

Compliance Department
Onosys
5005 Rockside Road, Suite 1100
Independence, OH 44131
United States

Request Demo.

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