Privacy Policy

Last update: January 01, 2023

Please read this privacy policy (the “Policy”) carefully to understand how Onispot, owned by CALLAS CONSULTING FZ-LLC, FDAM0429, Compass Building, Al Shohada Road, AL Hamra Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates (“Onispot”, “we”) uses personal information. By accessing or using www.onispot.com, the Onispot mobile app, or any other related sites, applications, services and goods, or any other website operated by Onispot that links to this policy (each, the “Site” or the “App”), you acknowledge that you have read and understood this Policy. This Policy may change from time to time; any changes we make to this Policy will be posted on this Site, we will also take any other steps, to the extent required by applicable law, including notifying you about material changes. Changes to this Policy are effective as of the stated "Last Updated" date. We recommend that you check the Policy periodically for any updates or changes.

Onispot and its affiliated companies is committed to protecting the personal information of its users - publishers, advertisers and other visitors browsing the Site (“users”) as well as affiliates, influencers and other collaborators interacting with Onispot. We believe that you have a right to know our practices regarding the information we collect when you visit and/or use the Site. This Policy explains our privacy practices for the Site and the App and services provided by Onispot as well as privacy practices that apply to affiliates, influencers and other collaborators who are individuals. By accessing and/or using the Site or the App and its related sites, applications, services, goods and/or registering for an account and/or registering to our affiliate or influencer or similar program, you acknowledge that you understand how we process your personal data in accordance with this Policy, including our collection, use, disclosure, processing and retention of personal information. You can also learn how to limit sharing of information in this Policy.

Information We Collect

Information You Provide. When you register to the Site, or the App, use it, complete forms, participate in skills tests or surveys, or use the Site or the App as collaborator, and/or register to our affiliate or influencer or similar program, we ask you to provide certain personal information, including a valid email address, Facebook, Snapchat, Twitter, TikTok, YouTube or Google, Instagram, Linkedin account login details and username. 

We will also ask you to provide or otherwise collect additional information, such as, your name, profile details, physical address or billing information, your geolocalization, telephone number or other contact details, transactional information, payment information (limited to the use of www.stripe.com policy, since we don’t directly process user’s credit cards), details about your lifestyle, details about your interests, details about your audience on your private profile of external social platforms, details about the generalusual topics of your content on your private profile of external social platforms, details about your generalusual appearance on your private profile of external social platforms, details about other social networks linked accounts, details about how you use your private social accounts of different external social platforms, details about your listed Onis, details about the actions you perform on Onispot, purchases and transactions you make throught the Onispot Site and App, details about your personal wallet inside Onispot, details about your awards and prizes you win, details about your Onis performances on your private profile of external social platforms, education, profession and expertise, information and files uploaded by you to the Site or the App, information and details about the content and files you generate on Onispot, and additional authentication information (such as copies of your government issued ID, passport, or driving license, as permitted by applicable laws). We also collect information about or contained in your communications with Onispot as well as any of your posts on our blogs or forums and your communication with other users of Onispot.

Information We Collect Automatically. We collect information while you access, browse, view or otherwise use the Site. In other words, when you access the Site or the App we collect personal information on your usage of the Site or the App, including transactions (wallet to wallet through Onispot or via www.stripe.com) and communications with other users through the Site or the App, your searches, the pages you visited, the Onis you partecipate to, as well as other actions on Site the App. We also may collect, use and process the information relating to such usage, including geo-location information, IP address, device and connection information, browser information and web-log information. We also collect and process information relating to the use of cookies and similar technologies, as detailed below. We use that information to provide you our services, enhance user experience, personalize your browsing experience as well as monitor the Site or the App for preventing fraud and inappropriate content or behaviour. 

Additionally, in order to improve your online experience at Onispot, we have implemented impression reporting. While you view our ads, we gather user Global Unique Identifier, HTTP request data like, user agent, IP, host, URL, country/continent from which request made, browser info, device/operating system/operating system version.

Information We Receive from Third Parties. We receive information from third party vendors and/or other commercially available sources, such as:

• Third party vendors who provide us data to supplement the information we collect about you, in accordance with applicable laws. For example, we receive fraud warnings from service providers for our fraud prevention and risk assessment efforts. We also receive information from enrichment service providers to enhance and personalize your experience as well as from advertising and marketing partners in order to manage and measure our campaigns. 
• If you link, connect, or login to your account with a third-party service (e.g. Google, Facebook, LinkedIn, ecc), we receive certain information, such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
• If you choose to invite contacts from your G-suite directory, we will have the ability to view details of contacts, subject to your G-suite permission. We will use this data to allow you to invite your contacts to your Onispot account. We will also use aggregated anonymised information for our internal purposes.
• If you integrate into your account information from third parties or otherwise integrate your account with third party systems, tools or products, we will receive certain information about you according to your permissions at such third parties. 
• We also receive certain information about you, if you are invited to Onispot by another user (for example, as part of our collaboration tools and referral program), in such case we will receive limited information, such as your email address or other contact information, and we will use it for the same purpose it was provided and in accordance with the terms of this Privacy Policy.

We combine your personal information with information we collect automatically or obtain from other companies and use it for the purposes detailed in this Policy. 

Our Legal Basis for Using Your Personal Information

Where relevant under applicable laws, all processing of your personal information will be justified by a "lawful ground" for processing. In the majority of cases, processing will be justified on the basis that:

• you have provided your consent for us to use your personal information for a specific purpose; 
• our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with services which you have purchased); 
• the processing is necessary to comply with a relevant legal obligation or regulatory obligation that we have (e.g. fraud prevention); or 
• the processing is necessary to support our legitimate interests as a business (e.g. to improve our services to you), subject to your interests and fundamental rights and provided it is conducted at all times in a way that is proportionate.

How Do We Use The Information Collected?

We will use your personal information for the following purposes:

• to provide you with quality service and security, to operate the Site or the App, to perform our obligations to you and to develop and improve our service. We also use this information to establish and set up your account, verify or re-issue a password, log your activity, provide customer support and contact you from time to time. The information helps us to develop and improve our services, to understand and analyse our performance as well as your preferences and performance and to customize and personalize our service and enhance your experience (including by making Oni suggestions, ranking search results, etc.). 
• to ensure marketplace integrity, prevent fraud and maintain a safe and secure marketplace and services. For example, we use personal information to monitor, track and prevent fraudulent activities and other inappropriate activities, monitor content integrity, conduct security investigations and risk assessments, verify or authenticate information provided by you, enforce our Terms of Service and comply with applicable laws. We conduct certain behavioural analytics to achieve the above objectives and in limited cases, if we detect activity that we think poses a risk to the Onispot marketplace, other users, our community, or third parties, automated processes may restrict or limit your ability to use Onispot. If you would like to challenge any such decision, please contact us at [email protected]. 
• to contact you, as requested by you or as otherwise approved by you or permitted according to this Policy. 
• to promote and advertise the Site or the App, our services and the Onispot marketplace. For example, we use the information collected from you for the purpose of sending direct marketing messages (as detailed below), to show you information that may be of interest to you, to organize and facilitate referral programs, contests or other promotional activities or events. 
• to maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations or as otherwise required by law.

We will ask for your consent before using information for a purpose other than those set out in this Policy.

Direct marketing:

• We use your personal information to send you direct marketing communications about our products, services or promotions from Onispot that may be of interest to you or our related services. This may be via email, post, SMS, telephone or targeted online advertisements. 
• Our processing of your personal information for marketing purposes is based on our legitimate interest, or on your consent, or as otherwise permitted according to applicable laws. You have a right to prevent direct marketing of any form at any time - this can be exercised by following the opt-out link attached to each communication or by sending an email to [email protected]. 
• We take steps to limit direct marketing to a reasonable and proportionate level, and to send you communications which we believe may be of interest or relevance to you, based on the information we have about you.

How Long Do We Keep Personal Information?

We apply a general rule of keeping personal information only for as long as is required to fulfil the purpose for which it was collected. However, in some circumstances, we will retain your personal information for longer periods of time. We will retain personal information for the following purposes:

• as long as it is necessary and relevant for our operations, e.g. so that we have an accurate record of your dealings with us in the event of any complaints or challenge; and 
• in relation to personal information from closed accounts to comply with applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Site or App terms and take other actions as permitted by law.

Children 

This Site or the App is offered and available to users who are at least 18 years of age or older and of legal age to form a binding contract. Minors under 18 and at least 13 years of age, are only permitted to use the Site or the App through an account owned by a parent or legal guardian with their appropriate permission. Minors under 13 are not permitted to use the Site, the App or the Onispot services. We do not knowingly collect personal information from children under 13. Parents and guardians should at all times supervise their children's activities. If we learn we have collected or received personal information from a child under 13, we will delete that personal information. If you believe we might have any information from or about a child under 13, please contact us at [email protected]. 

Sharing Personal Information with Third Parties

We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent.

We share your personal information with third parties as detailed below: 

• With other users and Site visitors. Once you register, your username, country, and additional information regarding your activity is made public and is visible to all users of the Site or the App. This information includes photos you upload, your published portfolio, Oni information, ratings, and additional information you may choose to add to your profile. We also may offer you the opportunity to participate and post content publicly in forums, blogs and on other similar features. Please be aware that certain information, such as your user name and profile, together with the content uploaded by you, will be publicly displayed when you use such features. Your information will also be shared with other users when you message or otherwise communicate with such users. When you publish your information and/or share your data with other Onispot users, you do so at your own risk. If you choose to share personal information with other users, including Advertisers via Onispot, such personal information may be shared with other users as separate controllers. While Onispot our Terms of Service require Advertisers and Publishers to keep the information shared with them confidential, Onispot cannot ensure that all users will do so and it is your responsibility to ensure that other users will comply with your standards. 
• With Service Providers. We share personal information for business purposes with service providers that provide us with services for the purpose of operating the Site or the App, opening and operating your account as well as providing ancillary services and solutions. These include, among others, hosting services, billing and payment processors and vendors, CRM systems, forum hosting, community management services, data and cybersecurity services, web analytics and performance tools, translation tools, IT SaaS services, session recording, communication systems, mailing systems, data optimization and marketing services, data enrichment services, legal and financial advisors or technical consultants. Consistent with applicable legal requirements, we take appropriate technical and organizational measures to require third parties to adequately safeguard your personal information and only process it in accordance with our instructions; 
• For legal reasons. We share personal information with law enforcement agencies, public authorities or other parties in order to respond to a subpoena or court order, judicial process or to regulatory authorities, if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes; when we believe it necessary or appropriate to disclose personal information to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law, breaches of security, or breaches of this Policy; to respond to claims against us; and to protect the rights, property, or personal safety of Onispot, our customers, or the public; 
• For payments and fraud detection. We share personal information with payment processors, fraud detection agencies and similar third parties for the purpose of facilitating payments done via the Site or the App and securing the Site or the App and protecting it against fraud, unauthorized transactions (such as money laundering), claims or other liabilities; 
• With social media partners. Our Site or App may includes certain social media features, including single sign on features. We also may share limited personal information with such social media platforms and marketing partners, such as Facebook, Linkedin, Snapchat, TikTok, Instagram, Twitter, YouTube and Google, to promote our services or the Onispot marketplace. Such features and third party services collect certain information about you and may set a cookie to enable their functionality. Such third parties’ features are governed by their policies. 
• With users with whom you interact. We share personal information to help facilitate interactions between users. For example, if you are an Advertiser we may share certain limited information about you (such as the fact it is your first purchase on Onispot) with the Publishers to ensure the services you receive from the Publishers will fit your needs; such sharing of information is limited in scope, and is only intended to improve the services provided by the Advertiser and your user experience;  
• In the context of a corporate transaction. Personal information will also be disclosed if we go through a business transition such as a merger, sale, transfer of all or a portion of Onispot's assets, acquisition, bankruptcy or similar event. In the event that we sell any business or assets, we will disclose your data to the prospective publisher. If we or substantially all of our assets are acquired by a third party, information held by us about our users will be one of the transferred assets. 

This Site or the App is also protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply with respect to data collected by reCAPTCHA. The use of Google reCAPTCHA is required in order to prevent fraud and misuse of the Site by use of automated machines. To learn more, please see Google's privacy policy.

Where We Store Your Personal Information

Some of the personal information you provide to us will be stored or processed on our behalf by third party suppliers and data processors and may be located in other jurisdictions, such as the United States and Israel, whose laws may differ from the jurisdiction in which you live. Whether to third parties or internally, there are also transfers of personal information from the European Economic Area (“EEA”) to countries outside of the EEA not deemed to provide an adequate level of data protection from a European data protection perspective, such as the United States. With regard to data transfers to such recipients outside of the EEA we provide appropriate safeguards, in particular, by way of entering into European Union (EU) standard contractual clauses as amended from time to time, and/or equivalent data transfer safeguards. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy.

Cookies

We use cookies and similar technologies (such as web beacons, pixels, tags, and scripts) to improve and personalize your experience, provide our services, analyze website performance and for marketing purposes. To learn more about how we and our third party service providers use cookies and your control over these Cookies, please see our Cookie Policy.

Do Not Track

Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. We do not honor browser requests not to be tracked online (known as “Do Not Track”), but our Cookie Policy describes how you can opt out of receiving cookies. 

External Links

Please note that the Site or the App contains links to third party sites and if you navigate to a third party site from the Site or the App, any data you provide to that site and any use of that data by the third party are not under the control of Onispot and are not subject to this Policy. You should consult the privacy policies of each site you visit. This Policy applies solely to personal information collected by our Site or our App. If you upload content, including personal information, to a social network (and even if you tag the Site or the App after that), your submission will be subject to that social network's terms of use and privacy policy, even where you post on an official Onispot page on the social network. We do not have control over these terms of use and privacy policies and have not reviewed their adequacy. You should therefore review these before submitting any personal information.

Security

We implement technical and organizational measures to maintain the security of the Site and the App, our services and personal information and in preventing unauthorized access, loss, misuse, alteration, destruction or damage to it through industry standard technologies and internal procedures. In addition, we cannot ensure that any third party processing your personal information equally provides for confidentiality and integrity of your data in a secure way, since we signed no contract with these providers. The transmission of data via the internet is not completely secure, and although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to the Site or the App. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access. Users who have registered to the Site or the App agree to keep their password in strict confidence and not disclose such password to any third party. Further information about our data security practices can be provided on request.

Rights of EU, EEA and UK Users

This section of the Policy applies to you if you are in the EU, the European Economic Area (EEA) or UK. 

The Controller (within the meaning of the EU and UK General Data Protection Regulation (“GDPR”)) for the processing of personal data as described in this Privacy policy is: CALLAS CONSULTING FZ-LLC, FDAM0429, Compass Building, Al Shohada Road, AL Hamra Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates 

Under applicable EU regulation, you have the following rights in respect of your personal information: 

• to obtain information about how and on what basis your personal information is processed and to obtain a copy; 
• to rectify inaccurate personal information; 
• to erase your personal information in limited circumstances where 
  1. you believe that it is no longer necessary for us to hold your personal information; 
  2. we are processing your personal information on the basis of legitimate interests and you object to such processing, and we cannot demonstrate an overriding legitimate ground for the processing; 
  3. where you have provided your personal information to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal information; 
  4. where you believe the personal information we hold about you is being unlawfully processed by us; 
• to restrict processing of your personal information where:

• 1. the accuracy of the personal information is contested;
  2. the processing is unlawful but you object to the erasure of the personal information; 
  3. we no longer require the personal information for the purposes for which it was collected, but it is required for the establishment, exercise or defence of a legal claim;
  4. you have objected to us processing your personal information based on our legitimate interests and we are considering your objection; 

• to object to decisions which are based solely on automated processing or profiling; 
• where you have provided your personal information to us with your consent, to ask us for a copy of this data in a structured, machine-readable format and to ask us to share (port) this data to another data controller; 
• to obtain a copy of or access to safeguards under which your personal information is transferred outside of the EEA.

Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, to the processing of your personal data by us and we may be required to no longer process your personal data. Moreover, if your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your personal data will no longer be processed for such purposes by us.

In addition to the above, you have the right to lodge a complaint with a supervisory authority for data protection. Please note that the right of access and the right to erasure do not constitute absolute rights and the interests of other individuals may restrict your right of access or erase in accordance with local laws. 

We will ask you for additional data to confirm your identity and for security purposes, before disclosing data requested by you. We reserve the right to charge a fee where permitted by law. We will decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we will retain where necessary certain personal information for a limited period of time for record-keeping, accounting and fraud prevention purposes.

Specific Provisions for California Residents

This section of the Policy applies to you, if you are a California resident. 

During the last twelve (12) months we have collected the following categories of personal information from users: 

• Information that you chose to upload or otherwise provided by you to Onispot, which may include: 
  1. Identifiers and personal information, such as name, postal addresses, online identifiers, email addresses, passport number or driving license number, social security number; 
  2. Details about your usage your content of your private profiles of external social platforms;
  3. Details about you lifestyle and your appearence;
  4. characteristics of protected classifications, such as gender; facial image; audio, electronic or similar information; 
  5. professional or employment-related information; 
  6. education information; 
  7. commercial information;
  8. Audio or other sensory information, for example if you provide audio-based services on Onispot. 
• Information we collect when you use Onispot, including i.e.:

• 1. Identifiers and personal information, such as online identifiers, internet protocol (IP) addresses, access device and connection information such as browser type, version, and time zone setting and browser plug-in types and versions; 
  2. Details about your values (such as ratings, engagement, likes, post frequencies, ecc) and your content of your private profiles of external social platforms;
  3. commercial information, including services purchased, obtained, or considered, or other purchasing histories or tendencies; 
  4. Internet or other electronic network activity information, including, but not limited to log-in and log-out time, the duration of sessions, the content uploaded and downloaded, viewed web-pages or specific content on web-pages, activity measures; 
  5. Location information.

• Information that we collect or receive from third parties, such as service providers, advertisers, and third-party accounts you link with Onispot, including i.e.: 

• 1. Identifiers and personal information, such as name, online identifiers, email addresses, internet protocol (IP) addresses, access device and connection information such as browser type, version, and time zone setting and browser plug-in types and versions; 
  2. Professional or employment-related information; 
  3. Internet or other electronic network activity information, including, but not limited to log-in and log-out time, the duration of sessions, the content uploaded and downloaded, viewed web-pages or specific content on web-pages, activity measures; 
  4. Commercial information; and 
  5. Location information. 

• Inferences drawn from any of the information identified above to create a profile about you. 

We use the personal information that we collect or receive for the business purposes as described above.

We may disclose the above listed categories of personal information to third parties for business purposes as described above in the Privacy Policy. In the preceding twelve (12) months, we have disclosed all the categories of personal information detailed above for business purposes. 

As previously mentioned in this Policy, we do not “sell” (as such term is defined in the CCPA) personal information. 

You are entitled to the following specific rights under the CCPA, subject to certain exceptions, in relation to personal information related to you: 

• You have a right to request access to the personal information we have collected about you over the past 12 months, including: 
  1. the categories of personal information we collect about you; 
  2. the categories of sources from which the personal information is collected; 
  3. the business or commercial purpose for collecting your personal information; 
  4. the categories of third parties with whom we have shared your personal information;
  5. the specific pieces of personal information that we have collected about you.
• You have a right to request that we delete personal information related to you that we collected from you under certain circumstances and exceptions. 
• You also have a right not to be discriminated against for exercising your rights under the CCPA. 
• You also have a right to submit your request via an authorized agent. If you use an authorized agent to submit a request to access or delete your personal information on your behalf, the authorized agent must: 

• 1. be a person or business entity registered with the California Secretary of State to conduct business in California; 
  2. provide proof of such registration; and 
  3. provide documentation or other proof indicating that they are authorized to act on your behalf. We may also require you to verify your identity directly with us, and directly confirm with us that you provided the authorized agent permission to submit the request. 

To make such requests, we kindly ask that you to contact us at [email protected]. 

We will verify your request using the information associated with your account, including email address. Government identification may also be required. 

A request for access can be made by you only twice within a 12-months period. Any disclosures that we provide will only cover the 12-months period preceding receipt of your request. We do not charge a fee to process or respond to your verifiable User request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for such decision and provide you with a cost estimate before processing further your request. 

Updating Personal Information

We take steps to ensure that the personal information we collect is accurate and up to date, and we provide you with the opportunity to update your information through your account profile settings. In the event that you believe your information is in any way incorrect or inaccurate, please let us know immediately. We will make sure we investigate the matter and correct any inaccuracies as quickly as possible where necessary or give you ways to update it quickly or to delete it - unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we will ask you to verify your identity before we can act on your request. If for any reason you have a problem with deleting your personal information, please contact Onispot's Customer Support at [email protected] and we will make reasonable efforts to delete any such information pursuant to any applicable privacy laws. 

You can review and change your personal information by logging into the Site or the App and visiting your account profile page. 

however, in order not to compromise the internal functioning of Onispot, to maintain an adequate level of reliability of targeting for the creation and targeting of Onispot Oni, and to prevent the proliferation of fraudulent actions, some information provided by the user, such as, for example, the public audience of reference of Publishers, or the topics covered in the content posted on the private profiles of external social platforms, or lifestyle, or appearance, can be changed only once and only after 30 days from the date of creation of your profile.

We strictly recommend users to pay attention when the provide us with these data.

If you delete your User Generated Content (“UGC”), as defined in the Onispot Terms of Service, from the Site, copies of your UGC may remain viewable in cached and archived pages, or might have been copied or stored by other Site users. Proper access and use of information provided on the Site, including UGC, is governed by our Terms of Service.

Contact Us

To exercise any of your rights in connection with your personal information, we kindly ask that you contact us at [email protected]. 

If you have any questions (or comments) concerning this Policy, please email our team at [email protected], and we will make an effort to reply within a reasonable timeframe.