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PRIVACY POLICY

OYO Digital Privacy Policy

Last updated: May 26, 2021

OYO Digital, LLC (“we,” “our,” “OYO”) provides a variety of data marketing, business, and business-to-business and consumer analytics products, technologies, and services (the “Services”) designed to inform and include insights for our clients (“Clients”). Our solutions, as described on this website (or any other website on which this Privacy Policy is posted) (“Website” or “Websites”), are used for both online and offline marketing purposes. When we say “you” we are referring to businesses and consumers, including the person reading this Privacy Policy.

We take very seriously the privacy interests of the individuals whose information we collect through our Services. We provide this Privacy Policy (“Privacy Policy”) to explain how we use and manage information collected through our Services, and the rights consumers have in order to control how their information is used and shared.

Our corporate Website is designed for our Clients, prospective clients and others who want to learn about our Services.

Our treatment of applicant, prospective applicant, and other prospective employment related information is described in this Privacy Policy.

When we handle information on behalf of Clients related to their own customers (and prospective customers), we do so as a service provider. We address these practices separately in this Privacy Policy.

  1. Information That We Collect and the Ways We Use It
    In order to provide our Services, we obtain information about you through the means discussed below. In addition to the purposes set out below, we may use all or a combination of this information to detect or prevent fraud, and to defend our legal rights and comply with the law. OYO Digital also receives information through its corporate Website. We may combine the information that we collect through the Services with information that we collect automatically or receive from other sources.

    While working with our clients, we collect:

    • Commercial transactions from our clients with the intent of providing better marketing to our Client’s customers including adding or suppressing customers from marketing campaigns.
    • Demographic, firmographic, and statistical data with the intent of providing better marketing to our Client’s customers by including or excluding them from marketing campaigns.
    • Device, internet, network, and electronic information for the purposes of targeting or excluding our Client’s customers from marketing campaigns.
  2. Business reasons for Collecting and Using Corporate and Personal Information (examples)

    The following provides additional information about our purposes for collecting and using your information – in effect, key aspects of our Services:

    • Provide marketing information to our Clients, regarding their marketing, customer engagement, and outreach activities.
    • Help our Clients identify and understand their customers better, by providing insights about customers and more commonly groups of customers.
    • Assist our Clients with use our Services to provide their customers and prospective customers with better service, improved offerings, and special promotions, for instance, advising on which customers are most likely to be interested (or disinterested) in certain offers.
    • Target and create defined audience segments based on common data and engagement attributes. When we do this, we work with our Client data and OYO collected data to perform these Services.
    • Provide “verification” or data “hygiene” services, which is how companies update and/or “clean” their databases by either verifying or removing or correcting old, incorrect or outdated information.
  3. Sharing Information with Third Parties

    We share the information collected from and about our Client’s customers for the various business purposes as described above and we will only share this information with our clients.  We do not sell data that we collect to any other Third-Party marketing or data analysis firms.

    All personal information collected through OYO Digital’s site is not sold and is securely maintained.

     Other ways in which we may share any of the information collected:

    • Sharing for Legal Purposes: In addition, we may share personal information with third parties in order to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of us, our platform, our clients, our agents and affiliates, its users and/or the public. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.
    • Sharing in Event of a Corporate Transaction: We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.
    • Aggregate and Deidentified Information: We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device. (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such Aggregate or De-Identified data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.
  4. Cookies and Similar Technologies

    a. Cookies
    OYO Digital and its business partners use certain industry-standard technologies, including cookies and similarly functional technologies, which we describe below. (We use these technologies on our Website, for instance, and our partners may use these technologies in their own marketing services.)

    We may work with third parties to provide or enhance our Services (e.g. for purposes of tailoring ads, or placing browser cookies), or to offer marketers ways to access or use our Information, often in de-identified form. These partners may set and access their own cookies, pixel tags and similar technologies on your device, which may have cookies with varying expiration periods. Those partners may, likewise, collect various types of information about your browser, device, or browsing activities through use of these cookies.

    Cookies, in turn, are small data files that contain a string of characters, such as a unique browser identifier. Cookies are stored on your computer or other device and act as tags that identify your device. Our (or other companies’) servers send your device a cookie when you visit a website. A pixel tag (also commonly known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is placed on certain web pages. When you access web pages (such as the website of a Client), pixel tags may permit our partners (or sometimes, us) to read the cookies that a respective company or server has deployed. Pixel tags are used in combination with cookies to track the activity on a site by a particular device.

    We and other online marketing platforms that we or they work with, may use cookies to, among other things, “remember” you, determine visitor patterns and trends, collect information about your activities on our clients’ sites, or interact with the advertising you see. Cookies are used in this way to provide relevant content to you and replace non-relevant communications with ads that better match your interests.

    Most web browsers are set up to accept cookies. You may be able to set your browser to warn you before accepting certain cookies or to refuse certain cookies. However, if you disable the use of cookies in your web browser, some features of our Website and other services may be difficult to use or become inoperable.

    c. Types of Cookies used by OYO Digital on our Sites
    Performance cookies: These cookies collect information about how visitors use our Sites for web analytics purposes. For instance, we may use cookies to analyze which pages visitors go to most often and if they receive any error messages. These cookies are used to help improve our Sites and your experience on our Sites. By using our Sites, you agree that we can place these types of cookies on your browser.

    Functionality cookies: These cookies allow our Sites to remember choices you make (such as remembering your username and password, language preference or the region you are in) and provide enhanced, more personalized features. These cookies may also be used to remember changes you have made to text size, fonts and other personalization. They may also be used to provide services you have requested, such as keeping you logged in to your account as you browse the internet. These cookies do not collect information about your browsing activity on other websites. By using our Sites, or by signing up for an account with us, you agree that we can place these types of cookies on your browser.

    Interest-Based Advertising cookies: For information on cookies that are used for interest-based advertising, please see below under Interest-Based Advertising.

    d. Alternate Tracking Technologies
    We, and our Clients, may use other technologies, such as beacons, tags and scripts, on our Site for analytics and administrative purposes. These technologies may be used in analyzing trends, administering the Site, recording users’ movements around the Site and gathering general information about our entire visitor base. We may receive reports based on the use of these technologies by these companies on an aggregated basis.

  5. Data Collected Through Our Website

    We will sometimes give you the opportunity to provide information directly to us through our corporate Website – such as if you are a business interested in a relationship with us or an individual requesting information about a job posting. Additionally, as you interact with our Website, we may use (or engage with business partners and vendors that use) automatic data collection technologies such as cookies (described above) to collect certain information about your equipment, browsing actions, and patterns.

    Any data collected through OYO’s website will be strictly used for its own purposes and will never be sold.

  6. Prospective Employment Information

    We may obtain personal information from you regarding any job postings to which you may apply, which may include name, email address, mailing address, phone number, and any other personal information contained in your résumé/CV that you submit through our Websites or otherwise provide to us.

  7. If OYO Digital considers your application or extends an offer of employment, OYO Digital may collect certain additional data either directly from you or from third parties such as background checks, where allowed by local law, with your consent. OYO Digital relies on your consent when collecting this data.

  8. Client data and how it supports OYO Services

    OYO Digital, as a service provider, provides its Clients with agency services as well as cross-media measurement and optimization services and marketing orchestration services. As an example, Clients leverage OYO’s services better identify customers who are most interested in a particular product or service. When our Clients provide us with information relating to their customer, prospective customers or other individuals, we handle it on behalf of our Clients as a service provider.

    Our Clients determine how to engage with their customers and thus act as the business that determines the purposes and means of handling customer or “CRM” data. Under these circumstances, Customers are ultimately subject to the privacy policy(ies) of the Clients controlling their data, and they should read those policy(ies) carefully. We are not responsible for the privacy practices of our Clients. Accordingly, this Privacy Policy and the rights acknowledged herein do not apply to data that OYO Digital handles on behalf of its Clients.

    As a service provider, OYO Digital may only process its Clients’ data upon instruction from the respective Client. (Accordingly, OYO Digital shares or discloses its Clients’ data to service providers, Clients, and Clients’ service providers per our Client’s instructions.) OYO Digital may also share Client data (1) to comply with applicable laws and regulations or to respond to a subpoena, search warrant or other lawful request for information received by us, whether or not a response is required by applicable law; (2) to enforce our terms of use and other agreements or to protect our rights; and (3) to protect the safety of members of the public and users of the service.

    While OYO Digital strongly encourages its Clients to adopt responsible approaches to its marketing practices, OYO Digital is not responsible for the information practices of such Clients.

  9. Choices and Access

    Client/prospect opt-out

    We maintain contact lists to communicate with our clients and prospects. Individuals must affirmatively ask to join one or more of our email lists by registering on our Sites. All email messages sent to these lists include an opportunity to unsubscribe or opt out of future email messages. You may also request to be removed from future email messages by contacting us at [email protected].

    We also maintain a postal mailing list to communicate with our clients and prospects. You can request to be removed from our mailing list by sending your name and postal address to us via email or postal mail to one of the addresses listed below under About Us.

    Access to Personal Information

    OYO Digital believes it is important to provide customers with clear information about the data available in our databases. If your personal information changes, or if you no longer desire our service, you may request to have information corrected or deleted contacting us at [email protected] or mailing us at the address listed on our About Us page at oyo.digital.

    Relevant Advertising Opt-Out

    You can opt out of relevant advertising through the following means:

    U.S. Visitors:

    You may opt out of our marketing databases. If we market to you by email, in our corporate capacity – such as if you are a Customer or prospective customer and we send information about our Services – you may “unsubscribe” from our marketing emails through a link placed in your emails.

    You can also opt out of online targeted ads (sometimes referred to as “interest-based” or “personalized” advertising), by visiting the opt-out portals operated the industry groups the National Advertising Initiative (NAI) or the Digital Advertising Alliance (DAA), and you can learn more about how those opt-outs work on those linked web pages. Please note that these online opt-outs are cookie-based. Therefore, if you browse the web from multiple browsers or devices, you will need to opt out from each browser and/or device, and for the same reason, if you change browsers or clear your browser cookie cache, you will need to perform this opt-out function again. Opting-out in this way will not prevent you from seeing all types of online ads; it generally will prevent targeted ads customized to what advertisers think may be most likely to be relevant and of interest to you.

    You may visit the Network Advertising Initiative (NAI) to learn more about its program and to opt out of the Interest-Based Advertising delivered by NAI members on web pages using cookies by visiting: http://www.networkadvertising.org/choices/.

    We adhere to the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Principles. You can visit the DAA to learn more about its program and to “opt out” of the online behavioral advertising delivered by its participants on web pages using cookies by visiting: http://www.aboutads.info/.

    “Do Not Sell My Personal Information” Notice for California consumers under California Consumer Privacy Act (CCPA)

    If you are a California resident, California law requires us to provide you with certain additional information regarding your rights with respect to your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). Please do not rely on the below information and disclosures in this section or otherwise directed to California residents if you are not a resident of California.

    i. Your California Privacy Rights

    CCPA Rights Disclosure. If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

    • Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.
    • Provide access to and/or a copy of certain personal information we hold about you.
    • Delete certain personal information we have collected from you (if any).
    • Provide you with information about the financial incentives that we offer to you, if any.

    The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.

    Please note that certain information may be exempt from such requests under California law. We also will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the type of request you are making, using a series of challenge questions.

    You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests (which we may ask to review) or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request. If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us via email at [email protected]

    European Union Visitors:

    We support the European Digital Advertising Alliance’s (“EDAA”) Self-Regulatory Principles. You can visit the EDAA to learn more about its program and opt out of the online behavioral advertising delivered by its participants on web pages using cookies by visiting: http://www.youronlinechoices.eu.

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

    If you are from the European Economic Area (EEA), OYO Digital 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.

    OYO Digital 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’s not overridden by your rights
    • For payment processing purposes
    • To comply with the law

    Your Data Protection Rights Under General Data Protection Regulation (GDPR)

    If you are a resident of the European Economic Area (EEA), you have certain data protection rights. OYO Digital aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

    If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

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

    • The right to access, update or to delete the information we have on 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 your Personal Data 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 OYO Digital relied on your consent to process your personal information.

    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. For more information, please contact your local data protection authority in the European Economic Area (EEA).

    Canadian Visitors:

    We support the Digital Advertising Alliance of Canada’s (“DAAC”) Self-Regulatory Principles. You can visit the DAAC to learn more about its program and opt out of the online behavioral advertising delivered by its participants on web pages using cookies by visiting: http://youradchoices.ca/choices/.

    Please note that these opt-outs operate by placing a cookie on your device that is unique to the browser you use to opt out. If you change browsers or computers, or delete the cookies on your computer, you will need to opt out again.

    For any questions related to our digital services, you may contact us via email at [email protected]

  10. Do Not Track

    Please note that, currently, OYO Digital does not honor browsers’ Do Not Track (DNT) signals, due the lack of clarity around the standards for the DNT signal.

  11. Retention

    OYO Digital retains your information for as long as you have an open and active account profile with us or as needed to provide you the services you requested. We will retain and use your information to comply with our legal obligations, resolve disputes and enforce our agreements.

    We will retain the minimum amount of personal information necessary to maintain a record of your opt-out if you choose to opt out of our communications.

  12. Links to Third Party Sites

    Our Site may contain links to unaffiliated third-party sites. We do not endorse or make any representations about any third-party sites (or any information, software or other products or materials found there) to which our site might link. This privacy policy does not apply to the information collection and use practices of third-party sites. We encourage you to review the privacy policies of these unaffiliated third-party sites to understand their data collection and use practices.

  13. Content Sharing Features

    Our site may include social media sharing features, such as LinkedIn and Twitter buttons, and may set a cookie to enable the feature to function properly. These features may collect your IP address and which page you are visiting on our Sites. Social media features are governed by that social media company’s privacy policy.

  14. Sensitive Information

    We ask that you not send or disclose any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) to us through our Sites or otherwise.

  15. Use of The Sites by Children

    Our Sites are not intended for children under the age of thirteen (13). We ask that children not provide personal information through our Sites. If we become aware that we have collected personal information from a child under the age of 13, we will delete this information from our records.

  16. Security and Data Integrity

    OYO Digital takes steps to help ensure that the data we possess is housed and transmitted securely. This may include various types of physical and electronic security, including firewall protections, encryption, or hashing of data, and access controls to personal information. While neither we nor any platform can guarantee 100 percent safety from hacks or illegal intrusion, we employ efforts that are designed to ensure that this does not occur.

  17. Changes to this Privacy Policy

    From time to time, we may update this Privacy Policy. Any changes are effective upon posting updates to our website. Please return to review any changes to this Privacy Policy.

  18. Storage of Information in the United States

    If you are accessing our Websites from a location outside of the United States, your connection will be through servers located in the United States and the Information you provide will likely be processed and securely maintained within the United States. Thus, you should be aware that in accessing this website or otherwise communicating with us, the information we collect or receive from you may be subject to laws with lesser or different privacy standards than those in your own country. We do respect local laws and will gladly update our records accordingly. If you have questions or a request, please send it to [email protected]

  19. Contact Us

    OYO Digital has a designated and definitive privacy contact. For questions or more information about OYO’s privacy policy and practices, email us or send correspondence to: