Privacy Policy

Introduction

Your privacy is important to us. Our policy is to respect your privacy and comply with all applicable laws and regulations regarding any personal information we may collect about you, including your use of our website and other sites we own and operate.

Personal information is any data relating to you that can be used to identify you. This includes information about you (for example, name, address, and date of birth), your devices, payment details, and even information about how you use a website or online service.

If our site contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following any link that leads you to third-party content, we encourage you to read the privacy policy posted by those third parties to understand how they collect and use personal information. This Privacy Policy does not apply to any of your activities once you leave our site.

This policy is effective as of March 7, 2024, and was last updated in April 2025.

Information Collection

The information we collect is categorized into two types: "voluntarily provided information" and "automatically collected information."

Voluntarily Provided Information: This refers to any information that you knowingly and actively provide to us when using or participating in our services and promotions.

Automatically Collected Information: This refers to any information that is automatically transmitted from your devices in the course of accessing our products and services.

Sign In Information

When you visit our website, our servers may automatically record the standard data provided by your web browser. This may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the date and time of your visit, the time spent on each page, and other details about your visit.

Additionally, if you encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical information about your device, what you were trying to do when the error occurred, and other technical information related to the problem. You may or may not receive notification of such errors, even at the time they occur, that they have occurred, or their nature.

Please be aware that while this information may not be personally identifying on its own, it could be combined with other data to identify individual persons.

Device Information

When you visit our website or interact with our services, we may automatically collect data about your device, such as:

- Device type
- Operating system
- Unique device identifiers
- Device settings
- Geolocation data

The information we collect may vary depending on your device's individual settings and software. We recommend that you review your device manufacturer's or software provider's policies to learn what information they make available to us.

Personal Information

We may ask you for personal information — for example, when you register for an account or when you contact us — which may include one or more of the following:

- Name
- Email address
- Phone/mobile number

Maintenance

1. The Operator reserves the right to continuously optimize and develop the Services. In the event of significant changes to the Services, the Operator will notify Users in a timely manner.

2. If the use of the Website or the Services is interrupted due to a disruption or failure, the Operator will make every reasonable effort to remedy such disruption or failure as soon as possible, but in no event later than 72 hours after becoming aware of the error.

3. The Operator reserves the right to temporarily restrict access to the Website and the Services when necessary to perform maintenance, development, or updates.

Legitimate Reasons for Processing Your Personal Information

We only collect and use your personal information when we have a legitimate reason for doing so. In such cases, we only collect the personal information that is reasonably necessary to provide our services to you.

Collection and Use of Information

We may collect personal information when you do any of the following on our website:

- Register for an account
- Use a mobile device or web browser to access our content
- Contact us via email, social media, or similar technologies
- Mention us on social media

We may collect, store, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:

- To provide you with the core features and services of our platform
- For analytics, market research, and business development, including to operate and improve our website, associated applications, and associated social media platforms
- To enable you to access and use our website, associated applications, and associated social media platforms
- For internal record-keeping and administrative purposes
- For security and fraud prevention, and to ensure that our sites and apps are safe, secure, and used in line with our terms of use
- For technical assessments, including to operate and improve our app, associated applications, and associated social media platforms

We may combine voluntarily provided personal information with automatically collected information, as well as with general information or research data we receive from other trusted sources. For example, our marketing and market research activities may yield insights and data that we may combine with information about how visitors use our site to improve both the site and your experience on it.

Security of Your Personal Information

When we collect and process personal information, and while we retain this information, we will protect it by commercially reasonable means to prevent its loss and theft, as well as unauthorized access, disclosure, copying, use, or modification.

Despite the fact that we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security.

You are responsible for choosing any password and its overall strength, and for ensuring the security of your own information within the bounds of our services. For example, by ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.

Retention Time of Your Personal Information

We retain your personal information only for as long as we need to. This period may vary depending on what we are using your information for, in accordance with this privacy policy. For example, if you have provided us with personal information when creating an account with us, we may retain this information for as long as your account remains active on our system. Once your personal information is no longer needed for this purpose, we will delete it or make it anonymous by removing all details that identify you.

However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation, or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.

Child Protection

We do not direct any of our products or services specifically at children under the age of 13, nor do we knowingly collect personal information about children under 13.

Disclosure of Your Personal Information

We may disclose personal information to:

- Our company's parent, subsidiary, or affiliate
- Third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing providers, professional advisors, and payment systems operators
- Our employees, contractors, and/or related entities
- Our existing or potential agents or business partners
- Credit reporting agencies, courts, regulatory authorities, and other competent bodies, in the event of your failing to pay for goods or services we have provided to you
- Courts, regulatory authorities, and law enforcement officers, when required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights
- Third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you
- Third parties for data collection and processing
- Any entity that acquires, or to which we transfer all or substantially all of our assets and business

Third parties we currently use include:
- Google Analytics

International Transfers of Personal Information

The personal information we collect is stored and/or processed in Ireland and Estonia, or wherever we or our partners, affiliates, and third-party providers have facilities.

The countries to which we store, process, or transfer your personal information may not have the same data protection laws as the country in which you initially provided the information. If we transfer your personal information to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this privacy policy.

Rights and Control of Your Personal Information

Your Choice: By providing personal information to us, you understand that we will collect, hold, use, and disclose your personal information in accordance with this privacy policy. You are not required to provide personal information to us, however, if you do not, it may affect your use of our website or the products and/or services offered on or through it.

Third-party Information: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Marketing Permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.

Access: You may request details of the personal information that we hold about you.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.

Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is essential to provide you with a particular service or offer (for instance, user support), 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, or provide you with a different level or quality of goods or services.

Data Breach Notification: We will comply with laws applicable to us in respect of any data breach.

Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details provided below and provide us with full details of the suspected breach. We will promptly investigate your complaint and respond to you in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory authority or data protection authority in relation to your complaint.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details provided in this privacy policy, or use the opt-out facilities provided in the communication. We may need to request specific information from you to help us confirm your identity.

Use of Cookies

We use "cookies" to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on the preferences you have specified.

Please refer to our Cookie Policy for more information.

Business Transfers

If we or our assets were acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information in accordance with this policy, which they will be required to assume as it is the basis for any ownership rights or usage we have over such information.

Limits in our Policy

Our website may contain links to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

Changes to our Policy

At our sole discretion, we may amend our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this privacy policy.

If the changes are significant, or if required by applicable law, we will contact you (based on your selected communication preferences) and all our registered users with the new details and links to the updated or amended policy.

As required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.

General Data Protection Regulation (GDPR) Compliance (EU)

Data Controller / Data Processor

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to the party or parties acquiring us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information in accordance with this policy, which they will be required to assume as it is the basis for any ownership rights or usage we hold over such information.

Legal Bases for Processing Your Personal Information

We will only collect and use your personal information when we have a legal right to do so. In such cases, we will collect and use your personal information lawfully, fairly, and transparently. If we seek your consent to process your personal information, and you are under 16 years of age, we will seek your parent’s or legal guardian’s consent to process your personal data for that specific purpose.

Our legal bases depend on the services you use and how you use them. This means that we will only collect and use your information on the following grounds:

Consent from you

When you give us your consent to collect and use your personal information for a specific purpose. You may withdraw your consent at any time through the means we provide; however, this will not affect the use of your information that has already taken place. By contacting us, you can authorize the use of your name and email address so that we can respond to your inquiry. While you can request at any time that we delete your contact information, it is not possible to retract emails that we have already sent. If you have further questions about how to withdraw your consent, please do not hesitate to contact us using the information in the "Contact Information" section of this privacy policy.

Performance of a Contract or Transaction

When you have entered into a contract or transaction with us, or in order to take preparatory steps prior to entering into a contract or transaction with you. For example, if you contact us with an inquiry, we may need personal information, such as your name and contact details, in order to respond.

Legitimate Interest

When we believe it is necessary for our legitimate interests, such as to provide, operate, improve, and communicate our services. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures taken to operate our services efficiently, marketing analysis, and measures taken to protect our legal rights and interests.

Cumplimiento con la Ley

In some cases, we may have a legal obligation to use or retain your personal information. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. If you have further questions about how we retain personal information to comply with the law, please do not hesitate to consult us using the information provided in the "Contact Us" section of this privacy policy.

International Transfers Outside the European Economic Area (EEA)

We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards. These include, for example, the use of standard contractual clauses approved by the European Commission, the use of Binding Corporate Rules, or other legally accepted means.

Your Rights and Control Over Your Personal Information

Restriction: You have the right to request that we restrict the processing of your personal information if (i) you are concerned about the accuracy of that information; (ii) you believe it has been unlawfully processed; (iii) you need us to retain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of evaluating your objection in relation to processing based on legitimate interests.

Objection to Processing: You have the right to object to the processing of your personal information that is based on our legitimate interests or the public interest. If you do so, we must provide compelling legitimate grounds that override your interests, rights, and freedoms in order to continue processing your personal information.

Data Portability: You may have the right to request a copy of the personal information we hold about you. Where feasible, we will provide this information in a CSV or other easily machine-readable format. You may also have the right to request that we transfer this personal information to a third party.

Erasure: You may have the right to request that we delete the personal information we hold about you at any time. We will take reasonable steps to delete your personal information from our current records. If you ask us to delete your personal information, we will let you know how the deletion affects your use of our website or products and services. There may be exceptions to this right for specific legal reasons, which we will describe to you in our response to your request if applicable. If you terminate or delete your account, we will delete your personal information within 1000 days of the account deletion. Please be aware that search engines and similar third parties may still retain copies of personal information that has been made public at least once (like certain profile information and public comments), even after you have deleted the information from our services or deactivated your account.

Contact Information

For any questions or concerns regarding your privacy, you can contact us using the following details:

To the Attention of the Legal Team:
legal@ocbo.io