OGANGI ONLINE PRIVACY AND DATA PROTECTION POLICY

Ogangi Corporation and its operating divisions, subsidiaries, affiliates and branches (collectively, “Ogangi,” the “Company,” “we” or “us”) are committed to protecting the privacy of information you provide to us. Accordingly, Ogangi provides this privacy and information practices statement to inform you about our online information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can correct or change such information (“Privacy Statement”).

SCOPE

Except as where otherwise indicated, this Privacy Statement applies to individuals who visit Ogangi’s websites (the “Sites”), use the Ogangi Platform, Ogangi’s mobile applications, mobile wallet passes, or other programs, services or offerings of Ogangi (together with the Sites and any and all future online and offline offerings operated by or on behalf of Ogangi, the “Services”).

Ogangi provides leading digital growth platform and related services (the “Platform”) for our enterprise customers around the world (“Customers”) to engage with their clients (“Users”) through various messaging channels, such as app notifications, email, sms, voice notifications, mobile wallet passes and in-app/in-browser messaging. When we Process Personal Information of Users in relation to our Customers’ use of the Platform, we Process such Personal Information as a service provider solely on behalf of our Customers in accordance with our agreements with Customers. Accordingly, this Privacy Statement does not apply to Users. If you are a User of one of our Customer’s digital properties, you should review that Customer’s privacy policy, terms or other notices to learn how that Customer collects and uses information about you, including through the Platform. 

TRANSPARENCY/NOTICE – WHAT PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT

The types of Personal Information we may collect (directly from you or from Third Party-sources) and our privacy practices depend on the nature of the relationship you have with Ogangi and the requirements of applicable law. Below are some of the ways we collect information and how we use it.

INFORMATION OGANGI COLLECTS

In general, Ogangi collects information from you based upon our business relationship, your use of our Sites and Services, and includes information that may be deemed Personal Information, such as title, name, address, phone number, email address, user name, Internet Protocol address, and billing and payment information related to payments for Services or programs.

HOW OGANGI COLLECTS PERSONAL INFORMATION

Some of the ways that Ogangi may collect your Personal Information include:

• Ogangi may collect Personal Information from you through various channels, including the Services, in surveys, during business or marketing events, and when delivering programs and Services to you.
• When you use the Services, Ogangi may provide you with opportunities to sign up to receive specific information and may ask for your contact information (e.g. name, company name, company address, phone number or email address), so that we can send you specific information about our products, Services, with your consent.
• As you navigate the Sites and use the Services, certain passive information may also be collected, including Internet Protocol addresses, cookies, navigational data, advertisements clicked, the name of the domain and host from which you access the Internet, the browser software you use and your operating system, your browser settings, your mobile device type, the date and time you access our Services and other device identifiers. This type of information is used for the purposes of gathering data to provide improved administration of our Services, and to improve the quality of your experience when interacting with our Services.

INFORMATION FROM THIRD-PARTY SOURCES

Ogangi may collect information about you from Third-Party sources to supplement information provided by you, including Internet Protocol addresses, cookies, navigational data and advertisements clicked. This supplemental information allows us to verify information that you have provided to Ogangi and to enhance our ability to provide you with information about our business, products and Services. Ogangi’s agreements with these Third Party-sources typically limit how the Company may use this supplemental information.

HOW OGANGI USES YOUR PERSONAL INFORMATION

Depending on how you interact with Ogangi, we and our Third Party-service providers may also use Personal Information in a variety of ways, including:

• Providing Information and Services You Requested. Ogangi may use the Personal Information about you to fulfill requests for programs, Services, or information that you may request, including information about potential or future Services, including to: (a) generally manage your information and accounts; (b) respond to questions, comments and requests; (c) provide access to certain areas and features of the Services; and (d) allow you to register for events or participate in webinars.
• Administrative Purposes. Ogangi may use the Personal Information about you for its administrative purposes, including, without limitation, to: (a) measure interest in the Services; (b) perform internal quality control; (c) verify identity; (d) send communications regarding the Services, your account, or any changes to any Ogangi policy or terms of use; (e) process payments; (f) prevent potentially prohibited or illegal activities; and (g) enforce our Terms of Use.
• Marketing Products and Services. Ogangi may use the Personal Information about you to provide you with materials about offers, products and services offered by us, including new content or information about future services on Ogangi Sites. Ogangi may provide you with these materials by phone, postal mail, facsimile or email, as permitted by applicable law. Such uses include: (a) to tailor content, advertisements, and offers; (b) to notify you about offers, products, and services that may be of interest to you; (c) to provide Services to you; (d) for other purposes disclosed at the time that you provide Personal Information; or (e) otherwise with your consent. If you do not wish us to use your Personal Information for marketing purposes, you may contact us at any time to opt out of the use of your Personal Information for such purposes, as further described below.
• Research and Development. Ogangi may use your Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products, processes and services.
• Other Uses. Ogangi may use your Personal Information for other purposes disclosed to you at the time you provide Personal Information or with your consent.

SOCIAL MEDIA

Generally, online social media resources are interactive tools that enable individuals to collaborate and share information with others. Social media resources include, but are not limited to, social networks, discussion boards, bulletin boards, blogs, wikis, and referral functions to share web site content and tools with a friend or colleague.

Ogangi may collect Personal Information to enable individuals to use online social media resources offered either by Ogangi or a Third Party. We may also enable you to use these social media resources to post or share Personal Information with others. When using social media resources, you should take into careful consideration what Personal Information you share with others.

If you use on online social media resource offered by a Third Party (“Third Party SMR”) through the Services, you acknowledge that Ogangi may be able to access any information you make public through such Third Party SMR (such as your username, comments, posts and contacts) and other information your privacy settings on such Third Party SMR permit Ogangi to access. Ogangi will comply with the terms of this Privacy Statement and the privacy policies applicable to the social media resources it uses.

EMAIL MARKETING

Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters or mailings from us with information on Ogangi or our business partners’ products and Services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the individual by following the instructions in the EMAIL COMMUNICATIONS section below.

ALL INTERNET USERS – COOKIES, PIXEL TAGS/WEB BEACONS, ANALYTICS INFORMATION, AND INTEREST-BASED ADVERTISING

COOKIES

Like many other websites, Ogangi or its business partners may employ a cookie, or small piece of computer code that enables Web servers to “identify” visitors, each time an Individual initiates a session on the Company’s Sites. A cookie is set in order to identify visitors; tailor our Sites to you; measure and research the effectiveness of our Sites’ features, offerings and advertisements; and authenticate users for registered Services. Cookies can only access Personal Information that you have provided on our Sites and cannot be accessed by other sites. Individuals also have the ability to delete cookie files from their own hard drive at any time by clicking on the Privacy or History tab typically found on the Settings or Options menu in your internet browser. However, please also be advised that cookies may be necessary to provide access to much of the content and many of the features of Ogangi’s Sites.

PIXEL TAGS/WEB BEACONS

Ogangi  may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow us to monitor the use of our Sites. A pixel tag can collect information such as the Internet Protocol (“IP”) address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the browser type and language; the device type; geographic location; and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable email, we or our Third Party-service providers may use “format sensing” technology, which allows pixel tags to let us know whether you received and opened our email.

ANALYTICS INFORMATION

We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Sites, and to develop website content. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/ . You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout .

INTEREST-BASED ADVERTISING

Through our Sites, Ogangi may in the future allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect anonymous, non-Personal Information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Ogangi related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.”

MOBILE DEVICES

Ogangi may provide websites, applications and online resources that are specifically designed to be compatible and used on mobile devices. Ogangi will collect certain information that your mobile device sends when you use such websites, applications or online resources, like a device identifier, location, user settings and the operating system of your device.

Mobile versions of Ogangi’s Sites may require that users log in with an account. In such cases, information about use of each mobile version of the website may be associated with user accounts. In addition, Ogangi may enable Individuals to download an application, widget or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to Ogangi to enable you to access user accounts and to enable Ogangi to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. Ogangi may use personal or non-identifiable information transmitted to the Company to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Statement or in other notices Ogangi provides.

ANONYMOUS AND AGGREGATED INFORMATION

Ogangi may use your Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Sites or other online Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Ogangi may use such information in a number of ways, including research, internal analysis, analytics and any other legally permissible purposes. We may share this information within Ogangi and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

CHOICE/MODALITIES TO OPT OUT

You have the right to opt out of certain uses and disclosures of your Personal Information, as set out in this Privacy Statement.

GENERAL

Where you have consented to Ogangi’s Processing of your Personal Information, you may withdraw that consent at any time and opt out by following the instructions in the RIGHTS OF ACCESS, RECTIFICATION, ERASURE AND RESTRICTION section below . Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out. Note that, due to the nature of the Services, you may have to provide the email or other identifying value that is associated with your Personal Information in order for Ogangi to segregate out the use and retention of such Personal Information.

Prior to disclosing Sensitive Data to a Third Party or Processing Sensitive Data for a purpose other than its original purpose or the purpose authorized subsequently by the individual, Ogangi will endeavor to obtain each individual’s explicit consent (opt-in). Where consent of the individual for the Processing of Personal Information is otherwise required by law or contract, Ogangi will comply with the law or contract.

EMAIL COMMUNICATIONS

An “Unsubscribe” button will be provided at the top or bottom of each email communications sent by Ogangi so that you can opt-out. However, we may continue to send transaction-related emails regarding products or Services you have requested in response to such request. We may need to send you certain communications regarding the Ogangi programs and Services and you will not be able to opt out of those communications – e.g., communications regarding updates to our Terms of Use or this Privacy Statement.

“DO NOT TRACK”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. At this time, there is no general agreement on how companies like Ogangi should interpret DNT signals. Therefore, Ogangi does not recognize or respond to browser-initiated DNT signals, whether that signal is received on a computer or a mobile device. For information about “do-not-track”, visit http://www.allaboutdnt.org.

ONWARD TRANSFER

INFORMATION WE SHARE

Ogangi does not sell or otherwise disclose Personal Information about you, except as described in this Privacy Statement or as you explicitly consent. Ogangi endeavors to require third parties to which it discloses Personal Information to protect Personal Information using substantially-similar standards to those required by Ogangi (and at least the same level of privacy protection as is required by this Privacy Statement).

SERVICE PROVIDERS

Ogangi may share Personal Information with our service providers that we have retained to perform Services on our behalf including (i) provision of IT and related Services; (ii) provision of information and Services you have requested; (iii) payment processing; and (iv) customer service activities. Payment information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders.

Ogangi has executed appropriate contracts with our service providers that prohibit service providers from using or sharing your personal information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.

BUSINESS PARTNERS

From time to time, Ogangi may partner with other companies to jointly offer products, services or programs (such as webinars, events or downloadable content). If you purchase, specifically express interest in or register for a jointly-offered product, service or program from or through Ogangi, the Company may share your Personal Information collected in connection with your purchase or expression of interest with our business partners. Ogangi does not control our business partners’ use of shared Personal Information and their use of such information will be in accordance with their own privacy policies. If you do not wish for your information to be shared in this manner, you may opt not to purchase or specifically express interest in a jointly offered product or service.

INFORMATION DISCLOSED FOR OUR PROTECTION AND THE PROTECTION OF OTHERS

We may disclose information about you: (i) if we are required to do so by law, court order or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation; (iv) to enforce Ogangi policies or contracts; (v) to collect amounts owed to Ogangi; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing Personal Information may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

INFORMATION DISCLOSED IN CONNECTION WITH BUSINESS TRANSACTIONS

We reserve the right to disclose or transfer any information we have about you in the event of a proposed or actual purchase, any reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of our business or of any of the business assets or shares (including in connection with any bankruptcy or similar proceeding). Should such an event occur, Ogangi will endeavor to direct the transferee to use Personal Information in a manner that is consistent with this Privacy Statement.

INTERNATIONAL TRANSFERS

Ogangi primarily stores Personal Information sent or collected via or by Ogangi in the United States, in the cloud, our servers, the servers of our affiliates or the servers of our service providers. To facilitate the Company’s global operations, the Company may transfer, store and access such information from around the world. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Ogangi, you consent to the storage of your Personal Information in these locations.

DATA PROTECTION ADDENDUM

While the data protection, privacy and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy, including offering a Data Protection Addendum (DPA) to our agreement.

RIGHTS OF ACCESS, RECTIFICATION, ERASURE AND RESTRICTION

YOUR PERSONAL INFORMATION

You may seek confirmation regarding whether Ogangi is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate or has been Processed in violation of applicable data protection laws. Where otherwise permitted by applicable law, you may email privacy@ogangi.com to request access to, receive (port), restrict Processing, seek rectification or request erasure of Personal Information held about you by Ogangi. Such requests will be Processed in accordance with local laws. Although Ogangi makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Ogangi is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Ogangi determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Ogangi will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

CUSTOMER DATA

As a data processor for our Customers, Ogangi Processes data that may include Personal Information of Users (“Customer Data”). Ogangi will not review, share, distribute or reference any such Customer Data except as provided in the agreements between us and our Customers, or as may be required by law. If Personal Information pertaining to you as an individual has been submitted to us by a Customer as Customer Data and you wish to exercise any rights you may have to access, correct, amend or delete such data, please inquire with the relevant Customer directly. Because Ogangi personnel have limited ability to access Customer Data, if you wish to make your request directly to Ogangi, please provide the name of the relevant Ogangi customer. We will refer your request to that Customer, and will support them as needed in responding to your request within a reasonable timeframe.

RETENTION

Ogangi retains the Personal Information we receive as described in this Privacy Statement for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our products and Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.

SECURITY

The security of all Personal Information provided to Ogangi is important to us, and Ogangi takes reasonable steps designed to protect your Personal Information. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while Ogangi strives to protect your Personal Information, we cannot ensure or warrant the security of information you transmit to Ogangi. You are responsible for maintaining the secrecy of your own passwords. If you have reason to believe that your passwords or Personal Information is no longer secure, please promptly notify Company at privacy@ogangi.com.

REDRESS/COMPLIANCE AND ACCOUNTABILITY

If after reviewing this Privacy Statement, you would like to submit a request or you have any questions or privacy concerns, please contact:

privacy@ogangi.com

Ogangi will address your concerns and attempt to resolve any privacy issues in a timely manner.

If you are an EU or Swiss citizen and feel that Ogangi is not abiding by the terms of this Privacy Statement, please contact Ogangi at the contact information provided above. If any request remains unresolved, you may contact the national data protection authority for your EU Member State.

OTHER RIGHTS AND IMPORTANT INFORMATION

INFORMATION REGARDING CHILDREN

Due to the nature of Ogangi’s business, Services are not marketed to minors. Ogangi does not knowingly solicit or collect Personal Information from children under the age of 13 (and in certain jurisdictions under the age of 16). This applies to any Personal Information directly collected by us, but does not apply to the Personal Information provided to us by Third Party services and organizations or from our Customers regarding Users (please refer to the terms of their respective Privacy Policies). If we learn that we have collected Personal Information from a child under the age of 13 (and in certain jurisdictions under the age of 16) in relation to the Services, we will promptly delete that information.

CALIFORNIA PRIVACY RIGHTS

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Ogangi does not share Personal Information with third parties for their own marketing purposes.

LINKS TO THIRD-PARTY DIGITAL PROPERTIES

Please note that our Services may contain links to other websites or digital properties for your convenience and information. Ogangi does not control Third-Party websites, digital properties or their privacy practices, which may differ from those set out in this Privacy Statement. Ogangi does not endorse or make any representations about Third-Party websites or digital properties. Any Personal Information you choose to give to unrelated Third Parties is not covered by this Privacy Statement. Ogangi encourages you to review the privacy policy of any company, website or digital property before submitting your Personal Information. Some Third Parties may choose to share their users’ Personal Information with Ogangi; that sharing is governed by that company’s privacy policy, not this Privacy Statement.

CHANGES TO THE PRIVACY STATEMENT

Ogangi may update this Privacy Statement from time to time as it deems necessary in its sole discretion. Ogangi will provide notification of any material changes to this Privacy Statement through the Company’s Sites or as otherwise required by applicable law. Ogangi encourages you to review this Privacy Statement periodically to be informed regarding how Ogangi is using and protecting your information and to be aware of any policy changes. Your continued relationship with Ogangi after the posting or notice of any amended Privacy Statement shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Statement take effect immediately after being posted or otherwise provided by Ogangi.

COMPLIANCE

This Privacy Statement shall be implemented by Ogangi and all its operating divisions, subsidiaries and affiliates. Ogangi has put in place mechanisms to verify ongoing compliance with this Privacy Statement. Any Employee that violates these privacy principles will be subject to disciplinary procedures.

DEFINITIONS

“Personal Information” is any information relating to an identified or identifiable natural person; an identifiable natural person is one who can 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.

“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU-residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the individual’s sex life; or (8) information relating to the commission of a criminal offense.

“Third Party” is any natural or legal person, public authority, agency or body other than the Individual, Ogangi or Ogangi’s agents.