Privacy Statement

Revised as of January 1, 2023

These websites are owned and operated by OSF Global Services, Inc. d/b/a OSF Digital (herein “OSF” or “We”). Your privacy while visiting our websites (collectively, the "Sites") is of the utmost importance to us. Because we gather certain types of information about our visitors, we believe it is important for them to understand the types of information we collect about them and how that information is used. This Privacy Statement only applies to information collected on the Sites, and will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not visit our Sites.

OSF is committed to protecting the privacy rights of its website visitors and to respecting regulations regarding the use of your Personal Data.

By definition, “Personal Data” means personal information relating to you, as an identified or identifiable natural person, which may allow the natural person to be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Therefore, the following Privacy Policy sets forth the principles OSF follows when visitors to our website submit Personal Data.

COLLECTION AND USE OF PERSONAL DATA

WHAT PERSONAL DATA WE COLLECT

OSF gathers two types of information about users:

• Personal Data that users provide through optional, voluntary submissions, for example registration to attend a seminar or webinar; registration to download an integration product; requests for information about OSF or our services; requests for a complimentary evaluation; participation in an online survey; or a job application.

• OSF gathers information about our visitors’ use of the Sites, as well as various aggregated tracking information derived mainly by tallying page views. This information allows us to better tailor our content to visitors' needs and to help us to better understand the demographics of our audience.

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.

Sensitive Information. We do not process sensitive information.

HOW WE USE YOUR PERSONAL DATA

The information you provide is used solely by OSF and its affiliated companies. We use this information to:

• Assess the needs of your business to determine suitable products;
• Send you requested product or service information;
• Send product updates or warranty information;
• Respond to customer service requests;
• Administer your account;
• Send you a newsletter;
• Send you marketing communications;
• Respond to your questions and concerns;
• Improve our website and marketing efforts;
• Conduct research and analysis;
• Display content based upon your interests;
• Support our recruiting activities;
• Save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm. For purposes specifically described when you provide the information or when we prompt you regarding a new use of information about you.

In summary, OSF will only use Personal Data in ways that are compatible with the purposes for which it was collected or subsequently authorized by you.

In accordance with applicable international regulations, including the EU General Data Protection Regulation (herein, “GDPR”): You have the option to opt-out of any secondary communications such as promotional communications by clicking on "unsubscribe" on the bottom of any OSF promotional email.

Further, consistent with international legislation, we will never knowingly request personally identifiable information from anyone under the age of 13 without requesting parental consent.

COLLECTION AND USE OF PERSONAL DATA FOR PRODUCT DOWNLOADS

When you register to download an OSF integration product (“plug-in”), we collect the following information in the product database:

• API Key ID and, when necessary, the third party application ID.

We will retain your Personal Data for as long as your account is active or as needed to provide you services or as reasonably necessary to comply with our legal obligations. We do not collect credit card or other personal financial information.

No extra data that is the property of the client is stored in the OSF plug-in application. We do not collect, store, use or tamper with proprietary data that is owned by you and is otherwise exchanged between the devices using the plug-in application.

LEGAL GROUNDS WE RELY ON TO PROCESS YOUR INFORMATION

We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you:

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
• Send users information about special offers and discounts on our products and services;
• Develop and display personalized and relevant advertising content for our users;
• Analyze how our services are used so we can improve them to engage and retain users;
• Support our marketing activities;
• Diagnose problems and/or prevent fraudulent activities;
• Understand how our users use our products and services so we can improve user experience.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

In legal terms, we are generally the “data controller” under European data protection laws of the personal information described in this privacy notice, since we determine the means and/or purposes of the data processing we perform. This privacy notice does not apply to the personal information we process as a “data processor” on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the “data controller” responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions.

WHERE WE STORE DATA

Storage and processing of the Personal Data is done in order to customize our products and services.

By submitting your personal data, you agree that we may transfer, store and process your data outside of the country in which you reside. Your data is stored in our systems for as long as necessary (but no longer than 5 years), and you can always ask us to view/edit/delete your data as mentioned in the “CORRECTING AND UPDATING YOUR PERSONAL DATA” section.

OSF will take reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy.

Alternatively, you may choose not to submit your Personal Data on OSF’s websites, however as a result, OSF may not be able to provide certain services to you.

DISCLOSURE TO THIRD PARTIES

We may make certain Personal Data available to strategic third-party business partners. They will not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. In all cases, Personal Data will only be shared to provide or improve our products, services and advertising. We do not sell, rentor trade your Personal Data with any third party. We only disclose Personal Data for the purposes of providing our Services, and as required by law.

We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

DISCLOSURES THAT MAY BE REQUIRED BY LAW

We may be required to provide certain Personal Data to comply with legally-mandated reporting, disclosure, or other legal process requirements.

CORRECTING AND UPDATING YOUR PERSONAL DATA

We offer settings to control and manage the personal data we have about you, including the ability to:

• Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide services to you).
• Amend or Rectify Data: You can ask us to amend your data in certain cases, particularly if it is inaccurate.
• Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
• Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

You may access, request deletion, and correct your personal data by either writing to us at dataprotection@osf.digital, Subject: Personal Data and OSF will reply to your request, by e-mail, or by using this form and ask to forget your information. We will respond to your request within an estimated period of 30 (thirty) days.

In addition, if you have any complaints regarding OSF, we will try to resolve all justified complaints in good faith. Website visitors can address their complaints to legal@osf.digital.

COOKIES AND OTHER TECHNOLOGIES

Like many companies, OSF uses automatic data collection tools on its websites, such as cookies and embedded web links. These tools collect certain standard information that your browser sends to our websites, such as your browser type and the address of the website from which you arrived at one of our websites. These tools may also collect information about your Internet Protocol (IP) address and clickstream behavior (for example, the pages you view and the links you click). Collectively, these tools help make your visit to our websites easier, more efficient and more valuable by providing you with a customized experience and recognizing you upon your return to our site.

A cookie itself does not contain Personal Data. The cookie can't read data off your hard drive or read cookie files created by other sites. Instead the cookie will enable us to relate your use of this site to information that you have specifically and knowingly provided to OSF. Standing alone, cookies do not personally identify you; they merely recognize your web browser. Unless you choose to identify yourself to OSF, either by responding to a promotional offer, registering to download a product, or filling out a web form (such as a “Contact Me”), you remain anonymous to OSF.

Upon your first visit to the OSF website we will ask for permission to enable cookies. You may not accept cookies, in which case you can still continue to the website but you may be unable to access certain services. You can always monitor our use of cookies on your computer by setting your web browser to inform you when cookies are set, or you can prevent the cookies from being set entirely. The "help" portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you disable the use of cookies on your computer, you may be unable to access certain services in our applications.

USAGE TRACKING

To improve the content and format of our websites, OSF uses industry standard web site tracking software to automatically capture user traffic patterns and technical information that is then stored in our servers' log files. This information may include, but is not limited to, user domain, the type of internet browser used, which web pages were visited, and the amount of time spent on our site.

We do not correlate this information with data about individual users. We do break down overall usage statistics according to a user's domain name, browser type, and MIME type by reading this information from the browser string (information contained in every user’s browser).

OSF sometimes tracks and catalogs the search terms users enter in our Search function, however this tracking is never associated with individual users. We use tracking information to determine which areas of our sites users prefer based on traffic to those areas. We do not track what individual users read, but rather how well each page performs overall. This helps us continue to build a better online experience for you.

SECURITY PROCEDURES

OSF follows industry standard physical and technical security measures, administrative controls and procedures to protect client data during transmission to us and to safeguard that Personal Data once we receive it. The Company hosts its websites in a secure server environment that uses firewalls, intrusion detection systems, and other advanced technology to prevent unauthorized access or access from outside intruders.

OSF operates secure data networks protected by industry standard firewall and password protection systems. We use HTTPS connections to transfer data through our plug-in applications; and only authorized individuals have access to the information provided by our clients.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the Sites within a secure environment.

Our security and privacy policies are reviewed and enhanced periodically.

THIRD-PARTY WEBSITES AND SERVICES

OSF web sites may contain links to other third-party web sites, products and services (collectively, "Linked Sites"). Such Linked Sites are offered for your convenience and/or information. OSF is not responsible for the contents or privacy practices of any Linked Site. Information collected by third parties may include location data or contact details. OSF makes no representations regarding the use of data by third-party websites-- third-party collection of data is governed by the privacy practices of those third parties. We encourage you to review the privacy statements posted on the sites you visit.

NOTIFICATION OF PRIVACY STATEMENT CHANGES

OSF reserves the right to change this Privacy Statement. OSF will provide notification of material changes to this Privacy Statement through the Company’s websites at least thirty (30) business days prior to the change taking effect. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. Only the current Privacy Statement is deemed effective, so we encourage you to periodically review this page for the latest information on our privacy practices.

WHAT ARE YOUR PRIVACY CHOICES?

• You may review and correct your Personal Data and preferences;
• You may opt-out of emails from us;
• You may submit requests to opt-out of phone and postal marketing.

REGULATORY COMPLIANCE

OSF has taken measures to be in compliance with applicable international regulations which govern the use of Personal Data, including GDPR. You can read OSF's commitment statement here.

NO UNLAWFUL OR PROHIBITED USE

You warrant to OSF that you will not use the Company’s websites for any purpose that is unlawful or prohibited by these terms, conditions and notices. You may not use the Company’s websites in any manner that could damage, disable, overburden or impair the websites or interfere with any other party's use and enjoyment of the OSF websites.

TRADEMARKS

The names of companies and products mentioned within any website owned and operated by OSF may be the trademarks of their respective owners.

APPLIES TO THESE WEBSITES:

osf.digital, osf.digital/en-gb/, osf.digital/fr-fr/, osf.digital/de-de/, osf.digital/pt-br/, osf.digital/es-es/, osf.digital/ja-jp/, osf.digital/en-au/

If you have questions or concerns regarding this policy, you may contact our Data Protection Officer (DPO), Alexandra Gazda, by email at alexandra.gazda@osf.digital. Also, for any complaints regarding our policies or OSF, please contact us at complaints@osf.digital or at legal@osf.digital.