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Privacy Policy

June 19, 2023

OVERVIEW

In order to operate the OMICRON Services and to prevent fraud and reduce its risk, OMICRON MARKETING LIMITED. (hereinafter“OMICRON”), a company duly organised and established under the laws of UK, bearing company registration number 14359103, and having its registered address at 240 PORTOBELLO ROAD LONDON ENGLAND W11 1LL acting as the data controller, is obliged to ask you to provide us with information about yourself, including your contact, and corporate details and sensitive data. By consenting to, and agreeing the terms of, this Privacy Policy, you agree to us processing your data in the manner set below. This Privacy Policy describes the collection and usage of information about you. We take the processing of your information very seriously and will use your information only according to the terms described in this Policy. For the purposes of this Privacy Policy, the term “information” and Personal Data means any confidential and/or personally identifiable information or other information related to users of OMICRON and/or related Services provided by OMICRON and through its subsidiaries, including but not limited to customers and merchants (legal entities). Your information will not be sold or rented to any third parties for their marketing purposes without your explicit consent. However, in order for us to offer OMICRON and/or related Services provided by OMICRON and through its subsidiaries, to our users; enhance the quality of Services from time to time; and protect the interests of our users, we will in limited circumstances share some of your information with third parties under strict restrictions. It is important for you to review this Privacy Policy as it applies to all the OMICRON Services. This Privacy Policy is intended to govern the use of OMICRON and/or related Services provided by OMICRON and through its subsidiaries, by our users (including, without limitation those who use the OMICRON Services in the course of their trade or business) unless otherwise agreed through contract.

Changes to this Privacy Policy:

All future changes to this Privacy Policy set out in the Policy Update already published on the OMICRON http://customsoftwaredev.uk/ website at the time you register for the OMICRON Services. All the changes will take effect as specified in the Policy Update. “Policy Update” means a prior notice of changes to any of your agreements with OMICRON which OMICRON may make available to you in writing. If you disagree with the terms of this Privacy Policy, please do not register for or use the OMICRON Services.

Notification of Changes:

This Policy may be revised and updated as new features are added to the OMICRON Services or as we incorporate suggestions from our customers. We may change this Privacy Policy at any time by posting a revised version of it on our website. Unless we have legal grounds to do otherwise, we will provide you with at least 30 days' prior notice of the effective date of the revised privacy policy. We may notify you about the changes in the Policy by posting the notice on the 'Policy page' of our website(s) and/or notify you by e-mail. In case you disagree with the terms of this Privacy Policy, you may close your account or request closing your account at any time. Please check the OMICRON or any websites on a regular basis for the most current version of our Privacy Policy. Third Party Websites: Some pages on the OMICRON website include links to third-party websites or our other products. These sites are governed by their own privacy statements (unless the product or link to the web site belongs to OMICRON), and OMICRON is not responsible for their operations, including but not limited to their information practices. Customers who submit information to or through these third-party websites should review the privacy statements of these sites before providing them with personally identifiable information.

A Special Note about Children: Children are not eligible to use OMICRON or other related Services and we ask that minors (persons under the age of 18) do not submit any personal information to us or use the OMICRON or Services.

The personal data that we use is set out in Part 5, below.

GENERAL PRINCIPLES

In accordance with this Privacy Policy, we comply with the following principles:

  • Processing activities must be lawful, fair and transparent.

  • Personal Data must be collected for specified, explicit, and legitimate purposes.

  • Personal Data may not be further processed in any way incompatible with those purposes. Processing operations for archiving, public interest, scientific and historical research, and statistical purposes shall be consistent with the original purpose.

  • Personal Data must be adequate and relevant and limited to the minimum necessary for the purposes for which they are processed.

  • Personal data must be accurate and, where necessary, up to date.

  • Personal Data should be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the data were processed. Personal Data may be kept longer for archiving purposes in the public interest and for historical, statistical or scientific purposes.

  • Personal Data may only be processed in a way that ensures the security of Personal Data.

PERSONAL INFORMATION WE COLLECT

Providing information to us is voluntary, but any refusal to provide such information may disable us to comply with legal obligations, enter into contract with you, respond to your requests, provide you with our Services, receive and process your request.

We collect information about you when you visit our Sites or use our Services, including the following:

  • Registration and use information.

  • Transaction and usage information.

  • Participant information.

  • Information about you.

  • Information that you choose to provide us to obtain additional Services or specific online Services.

  • Information about you from third-party sources – We obtain information from third-party sources such as merchants, data providers, and credit bureaus, where permitted by law.

  • Other information we collect related to your use of our Sites or Services
    In case we process Personal Data outside of the listed scope we will ask for your consent. You may, in any case, withdraw your consent and in that case OMICRON will no longer process your Personal Data for this purpose, without any negative consequences.

WHY DO WE KEEP PERSONAL DATA

We retain Personal Data to fulfil our legal obligations and for our legitimate business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If your Account is closed, we may take steps to mask Personal Data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Personal Data in accordance with this Privacy Policy.

WHY DO WE PROCESS PERSONAL DATA

We may Process your information for the following reasons:

  • To operate the Sites and provide the Services in accordance with our terms of use.

  • To manage our business needs and pursue our legitimate interest,such as monitoring, analysing, and improving the Services and the Sites’ performance and functionality. For example, we analyse User behaviour and perform research about the way you use our Services. For more information, please read our Cookie Policy.

  • To manage risk and protect the Sites, the Services and you from fraud by verifying your identity andhelping to detect and prevent fraud and abuse of the Sites or Services.

  • To deliver marketing materialsabout OMICRON products and online Services and the products and services of affiliated businesses. We may also Process your Personal Data to tailor certain Services or Site experiences to better match our understanding of your interests. In each case you have the right to object to our legitimate interest to perform marketing activities.

  • To provide personalised Services offered by OMICRON on third-party websites and online servicesWe may use your Personal Data and other information collected in accordance with this Privacy Policy to provide a targeted display, feature or offer to you on third-party websites. We may use cookies and other tracking technologies to provide these online services and/or work with other third-parties such as advertising or analytics companies to provide these online services. For more information, please read our Cookie Policy.

  • To provide you with location-specific options, functionality or offersif you elect to share your Geolocation Information through the Services. We will use this information to enhance the security of the Sites and Services and provide you with location-based Services, such as advertising, search results, and other personalised content.

  • To comply with our obligations and to enforce the terms of our Sites and Services,including to comply with all applicable laws and regulations.

  • To make it easier for you to find and connect with others,we may use your information you have shared with the Service to suggest connections between you and people you may know. For example, we may associate information that we learn about you through your and your contacts’ use of the Services, and information you and others provide to suggest people you may know or may want to transact with through our Services. Social functionality and features designed to simplify your use of the Services with others vary by Service.

  • To respond to your requestsfor example to contact you about a question you submitted to our customer service team.

SHARE OF PERSONAL DATA

We may share your Personal Data or other information about you with others in a variety of ways as described in this section of the Privacy Policy.

  • With other members of the OMICRON corporate family:

    We may share your Personal Data with members of the OMICRON family of entities to, among other things, provide the Services you have requested or authorised; to manage risk; to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements; and to help us manage the availability and connectivity of OMICRON products, Services, and communications.
  • With other companies that provide services to us (as data processors):We may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may, for example, provide you with Services, verify your identity, assist in processing transactions, send you advertisements for our products and Services, or provide customer support.

  • With other financial institutions that we have partnered with to jointly create and offer a product or service (as joint data controllers):We may share Personal Data with other financial institutions that we have partnered with to jointly create and offer a product, such as with Acquiring bank partners in connection with the OMICRON or its subsidiaries. These financial institutions may only use this information to market and offer OMICRON-related products, unless you have given consent for other purposes.

  • With the other parties to transactions when you use the Services, such as other Users, merchants, and their service providers.

  • With other third parties for our business purposes or as permitted or required by law.

  • With your consent:We also will share your Personal Data and other information with your consent or direction, including if you authorise an account connection with a third-party account or platform.

In addition, OMICRON may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why Users visit our Sites and use our Services. This data will not personally identify you or provide information about your use of the Sites or Services. We do not share your Personal Data with third parties for their marketing purposes without your consent.

HOW DO WE WORK WITH THIRD-PARTY PLATFORMS AND OTHER SERVICES

A significant benefit and innovation of OMICRON’s Services is that you can connect your Account with a third-party account or platform. For the purposes of this Privacy Policy, an “account connection” with such a third-party is a connection you authorise or enable between your Account and a non-OMICRON account, payment instrument, or platform that you lawfully control or own. When you authorise such a connection, OMICRON and the third-party will exchange your Personal Data and other information directly.

Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorising an account connection, you should review the privacy notice of any third-party that will gain access to your Personal Data as part of the account connection. For example, Personal Data that OMICRON shares with a third-party account or platform such as a social media account may in turn be shared with certain other parties, including the general public, depending on the account’s or platform’s privacy practices.

USE OF COOKIES

When you visit our Sites, use our Services, or visit a third-party website for which we provide online Services, we and our business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”) to recognize you as a User and to customise your online experiences, the Services you use, and other online content and advertising; measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety across our Sites and Services. Certain aspects and features of our Services and Sites are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Sites and Services may be limited or not possible.

Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not respond to DNT signals.

You may check our Cookies Policy for more details.

PRIVACY CHOICES AVAILABLE TO YOU

In accordance with the extent permitted by applicable laws, you have the right to request from OMICRON access, transfer, correction or erasure of your Personal Data, right to set limitations to processing of your Personal Data, as well as to object to some processing activities and to lodge a complaint with the competent data protection authority. You also have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effect.