This Policy outlines Ohmium International, Inc.’s and its affiliates’ (“we”, “us”, or “our”) practices in relation to the storage, use, processing, and disclosure of Personal Information that you have chosen to share with us or that we collect about you (including, for example, when you contact us through the “Contact Us” webpage or similar webpages available on our website https://ohmium.com/ (“Website”)). Personal Information means information that relates to or identifies a particular person or, subject to applicable law, household.
Certain jurisdictions require you to consent to the processing of your Personal Information, or otherwise require you to accept the terms of this Policy. In this regard and subject to the data protection laws that apply to you, by using the Website, you agree and consent to the collection, use, storage, disclosure, and sharing of your Personal Information as described in this Policy. Please contact us if you have questions about our practices in your country or region.
All references to “you” across this Policy are to an end user who (a) shares their Personal Information with us, or (b) whose Personal Information we collect or process.
You may review specific provisions of this Policy by clicking the links below:
- Personal Information that we Collect
- Sources of Your Personal Information
- Use of Your Personal Information
- Disclosures of Your Personal Information
- Links to Third Party Services
- Cross Border Transfers of Your Personal Information
- Data Security
- Data Retention
- Your Legal Rights
- Updates to this Policy
- Contact Us
1. PERSONAL INFORMATION THAT WE COLLECT
We may collect Personal Information about you in various ways, as described in the “Sources of Personal Information” section below. The information that we collect may include, for instance:
- Identity Data, such as your name, username, and any similar identifier.
- Contact Data, such as your address, email addresses, telephone numbers, and/or the content of a message or inquiry you may share with us.
- Applicant Data, such as your name, location, prior employment history, references, and/or curriculum vitae. In some instances, to the extent permitted and in accordance with applicable law, we may also collect information needed to address workplace accommodations or information contained in a criminal background check while reviewing your employment application.
- Technical Data, which includes your IP address, device ID, device type or other identifier, browser information including browser type and version, browser language preference, time zone setting and location, browser plug-in types and versions, web browser application details, corresponding location details, date and time stamp, operating system, and other technology on the devices you use to access the Website. For further information about the technical data we may collect about you, please review the “Cookies” section below.
- Usage Data, which includes information about how you use the Website and your activity within the sites, time spent using the Website, referring URL, and page views.
- Marketing and Communications Data, which includes your personal or business contact information as well as your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use, and share aggregated data, such as statistical or demographic data, for any purpose. Aggregated data could be derived from your Personal Information but is generally not considered Personal Information under law as it does not directly or indirectly reveal your identity.
Where we need to collect Personal Information by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us.
2. SOURCES OF PERSONAL INFORMATION
We use different methods to collect your Personal Information, including through:
- Direct Interactions. You provide us your Personal Information when you interact with us directly. This includes Personal Information you provide when you request marketing communications to be sent to you, or when you give us feedback or contact us, among other circumstances.
- Automated technologies or interactions. As you interact with the Website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this Personal Information by using cookies, server logs, and other similar tracking technologies.
- Third parties or publicly available sources. We may receive Personal Information about you from various third parties. For example, we collect Technical Data from analytics providers such as Google.
3. USE OF YOUR PERSONAL INFORMATION
We may use your Personal Information in the following ways:
- For our business purposes: We may process your Personal Information to complete a transaction you initiate, such as to perform the contract we are about to enter into or have entered into with you, or where it is necessary for our legitimate interests (or those of a third party) to the extent that your interests and fundamental rights do not override our interests.
- To personalize your experience: Your Personal Information helps us to better respond to your individual needs and provide you with a more personalized experience while using our Website.
- To improve our services: We continually strive to improve our service offerings based on the information and feedback we receive from you. When you provide us with feedback, we may collect some of your Personal Information to better respond to the feedback.
- For HR and Recruitment Purposes: We may process your Personal Data if you choose to apply for a position or job with us, including for recruitment, career development, and talent management purposes. We may also use your Personal Data to conduct employment-related checks, such as background checks, to the extent permitted under and in accordance with applicable local law.
- To send periodic emails, including marketing emails: The email address you provide may be used to send you marketing emails, information, and updates, in addition to occasional company news updates and notices related to us or our business.
- To comply with legal obligations, such as reporting obligations or to comply with a court order.
- Otherwise, as permitted by applicable law.
Where applicable laws permit us to, we rely on your consent as a ground to process your Personal Information.
Where applicable law does not permit us to rely on your consent to process your Personal Information, we rely on the following legal bases for the processing of your Personal Information:
- Legitimate interests, which means our interest in conducting and managing our business to enable us to provide you with a better, more secure experience. Where required by applicable law, we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. In such instances, we do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect to specific activities by contacting us.
- Performance of a contract, which means we process your Personal Information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- To comply with a legal obligation, which means processing your Personal Information where it is necessary for compliance with a legal obligation that we are subject to.
We will only use your Personal Information for the purposes for which we collected it or as otherwise permitted by applicable law, such as when further processing may be compatible with the original purpose of collection. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us as stated below in the “Contact Us” section. If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so where such notice is required by applicable law.
Please note that we may process your Personal Information without your knowledge or consent where this is required or permitted by law.
4. DISCLOSURES OF YOUR PERSONAL INFORMATION
- Internal third parties, which are other companies within the Ohmium group of companies.
- External third parties, such as third parties who assist us in operating the Website, providing us with services, and conducting our business, as permitted by applicable law; and regulators and other bodies, as required by law or regulation.
- Third parties in relation to a corporate transaction, including third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If our business undergoes a change, then the new owners will use your Personal Information in the manner set out in this Policy.
To the extent required by applicable laws, we require third parties to respect the security of your Personal Information and to treat it in accordance with the law. We do not allow such third-parties to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.
Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enables the sites or service provider’s systems to recognize your browser and capture and remember certain information. For the purpose of this Policy, cookies also include similar technologies, such as pixels, web beacons and social network plug-ins (collectively, “cookies”).
We use the following cookies:
- Essential Cookies. These cookies are sometimes called “strictly necessary” cookies and are required for the operation of our Website. Without these essential cookies, the Website will not perform as smoothly as we would like it to, and we may not be able to provide the Website or certain services or features that you request.
- Analytical or Performance Cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that you find what you are looking for easily. Currently, we use Google Analytics cookies for this purpose. For more information about Google Analytics, please refer to “How Google Uses Information From Sites or Apps that Use Our Services,” which can be found at https://policies.google.com/technologies/partner-sites, or any other URL that Google may provide from time to time.
- Functionality Cookies. These are used to recognize you when you return to our Website. This enables us to personalize our content for you.
Most web browsers automatically accept cookies, but you may block cookies by activating the setting on your browser that permits you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or part of the Website.
6. LINKS TO THIRD PARTY SERVICES
7. CROSS BORDER TRANSFERS OF YOUR PERSONAL INFORMATION
The Personal Information that we process about you may be transferred to countries other than where you are based. For example, we may transfer your Personal Information to the United States of America where our servers are located. If you are based in the European Union, United Kingdom, or Switzerland, we generally rely on standard data protection clauses that are approved by local regulators for the onward transfer of your Personal Information.
You can find out more about these transfer mechanisms by contacting us as set out below in the “Contact Us” section.
8. DATA SECURITY
We have put in place appropriate technical and organizational measures to prevent your Personal Information from being accidentally lost, used, accessed, altered, or disclosed without authorization.
9. DATA RETENTION
We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you, among other purposes. Incase your Personal Information is no longer required for any purpose of lawful processing, then we will delete it in accordance with our internal data retention procedures.
In some circumstances, we may anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information for longer than our typical retention period without further notice to you.
10. YOUR LEGAL RIGHTS
Subject to the data protection laws that apply to you, you may have the right to:
- Request access to your Personal Information. This enables you to receive a copy of the Personal Information we hold about you.
- Request confirmation as to whether or not your Personal Information is being processed.
- Request the correction of the Personal Information that we hold about you. This enables you to have incomplete or inaccurate Personal Information we hold about you corrected, though we may need to verify the accuracy of the new Personal Information you provide to us.
- Request the erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information in limited circumstances. For instance, you also may have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which we will notify you of, if applicable, at the time of your request.
- Object to processing of your Personal Information. You may have the right to object to processing where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing, such as if you believe the processing impacts your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your Personal Information which override your rights and freedoms.
- Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios:
- If you want us to establish the Personal Information’s accuracy.
- Where our use of the Personal Information is unlawful, but you do not want us to erase it.
- Where you need us to hold the Personal Information even if we no longer require it, such as if you need it to establish, exercise or defend legal claims.
- You have objected to our use of your Personal Information, but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, and machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you, among other grounds of processing.
- Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us as described in the “Contact Us” section below.
We may need to request specific Personal Information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within a reasonable time, and, in any event, within the time period required by applicable law. Occasionally it may take us longer to process your request, such as if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated as to when we expect to be able to process your request.
11. UPDATES TO THIS POLICY
We may occasionally update this Policy. As such, we request that you regularly review this Policy. If we make material changes to this Policy, we will notify you of the changes through the Website or through other means, such as email if and to the extent required by applicable law. To the extent permitted under applicable law, by using our Website after such notice, you consent to updates made to this Policy.
We encourage you to periodically review this policy for the latest information on our privacy practices. We will also make prior versions of our privacy policies available for review.
12. CONTACT US
If you have any questions on this Policy, questions on how we process or handle your Personal Information, or otherwise, you may reach out to us with your grievances, feedback, and comments. Our contact details are:
Contact: Anne Kamosso, Senior RegulatoryCounsel and grievance officer
Please include the words “Privacy Inquiry” in the subject line of your email
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.
Last Updated: Nov 7, 2022