OSMOSIS TECHNOLOGIES (we) are committed to protecting your personal data and respecting your privacy.
• The Osmosis One V.10 mobile application software (App), once you have downloaded a copy of the App onto your mobile telephone or handheld device (Device).
• Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
IMPORTANT INFORMATION AND WHO WE ARE
OSMOSIS TECHNOLOGIES LLC, a Delaware limited liability company, is the data controller (collectively referred to as “we”, “us” or “our” in this policy).
Attn: Data Privacy Manager
Osmosis Technologies LLC
53 Bridge St, Brooklyn
NY 11201, USA
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues or other competent supervisory authority of an EU member state if the App is downloaded outside the UK. In compliance with the Privacy Shield Principles, Osmosis Technologies commits to resolve complaints about our collection or use of your personal information. The Federal Trade Commission has jurisdiction over Osmosis Technologies’ compliance with the Privacy Shield. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Osmosis Technologies at:
Attn: Data Controller
Osmosis Technologies LLC
53 Bridge St, Brooklyn
NY 11201, USA
Osmosis Technologies has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim for more information or to file a complaint. The services of JAMS are provided at no cost to you.
This version was last updated on July 3, 2019. It may change and if it does, these changes will be posted on this page (www.osmosis.one/privacypolicy) and, where appropriate, notified to you when you next log in to the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
Third party links
Our Services Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
THE DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about you as follows:
• Identity Data.
• Contact Data.
• Device Data.
• Content Data.
• Profile Data.
• Usage Data.
• Location Data.
We explain these categories of data below.
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 data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
HOW IS YOUR PERSONAL DATA COLLECTED?
We will collect and process the following data about you:
• Information you give us. This is information (including Identity and Contact data) you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
• Location Data. We may use your IP Address to determine your current location.
• Information we receive from other sources. We will receive personal data about you from
• Your employer where they have subscribed to our App and enabled you as a user. This data may include Identity, Contact, Profile, and Location Data.
• Device Data from the following parties:
• Analytics providers such as Google Analytics, Sentry, Firebase, and Zendesk which may be based outside the EU.
• Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us for bug tracking an analytics purposes.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
• Where you have consented before the processing.
• Where we need to perform a contract we are about to enter or have entered with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
See the Glossary section below to find out more about the types of lawful basis that we will rely on to process your personal data.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
In cases where your employer has not enabled Single Sign On (SSO), we share your email address with an email services (Mailgun) to send login codes to enable you to log in to the app. In cases where you ask to receive your login code via text message, we share your cellphone number with an SMS service (Twilio). To monitor the performance of the app, we share Usage, Location, and Device Data with Google Analytics, Sentry, Firebase, and Zendesk. Otherwise, we only share your data with a third party if required to do so by law, including to meet national security or law enforcement requirements. The privacy shield provision regarding liability for the actions of agent processors does not apply because we will not transfer personal information to third parties.
PRIVACY SHIELD FRAMEWORK
POSSIBILITY OF BINDING ARBITRATION
An individual has the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. For more information, visit:
We will hold your personal data on our account with Amazon Web Services (AWS) on servers which may be located in the United States. We have adopted safeguards to keep your personal data secure and are registered with the EU-US Privacy Shield framework. See our full Privacy Shield Compliance Statement at this URL: www.osmosis.one/eu-usprivacyshield.
All information you provide to us is stored with AWS on secure servers. Details of AWS data security is available here: https://docs.aws.amazon.com/aws-technical-content/latest/aws-overview/security-and-compliance.html. Some of the data on AWS is managed by MongoDB Atlas, a Privacy Shield-Compliant data management service. Details of MongoDB Atlas data security are here: https://docs.mongodb.com/manual/security/.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We will collect and store personal data on your Device using application data caches and browser web storage.
Certain Services include the ability to share user-generated content with other Services users. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
We will retain your data for the duration of your employer’s Subscription Term to the Osmosis platform, and will be deleted one (1) month after the expiry of that Subscription Term. Your employer may terminate your access to the App by giving notice to us.
In some circumstances you can ask us to delete your data: see YOUR LEGAL RIGHTS below for further information.
In some circumstances we will anonmize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
Please review the Glossary below to find out more about these rights:
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request transfer or your personal data.
• Right to withdraw consent.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us.
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data 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 of specific activities by contacting us.
Performance of Contract means processing your data 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.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
YOUR LEGAL RIGHTS
You have the right to:
Right of access - You have the right to ask us for copies of your personal information.
Right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
Right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances.
Right to object to processing - You have the right to object to the processing of your personal data in certain circumstances.
Right to data portability - You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
Right to withdraw consent at any time - Where we are relying on consent to process your personal data. 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
DESCRIPTION OF CATEGORIES OF PERSONAL DATA
• Identity Data: First name, last name, username or similar identifier, title, supervisor name, geographic base.
• Contact Data: Email address and telephone number.
• Device Data: Includes the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, and time zone setting.
• Content Data: includes information that you elect to post on the App when you use of the App.
• Profile Data: includes your username and password and data that may be transmitted from your employer’s HR system, including your job title, division, department, supervisor name and geographic base.
• Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites, including login, logout, errors/bugs, content posting events, and content interaction events.
• Location Data: includes your current location as disclosed by your IP address, your employer's HR system, or your device GPS hardware/software.