Privacy Policy

At Ontra, we take your privacy seriously. Please read this Privacy Policy to learn how we treat personal data.

Remember that your use of Ontra’s Services is at all times subject to our Terms of Service, which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Service.

Privacy Policy Table of Contents

1. Scope
2. Personal Data We Collect
3. How We Use Personal Data
4. How We Disclose Personal Data
5. Your Choices and Rights
6. Data Security
7. Data Retention
8. Personal Data of Children
9. International Data Transfers
10. Accessibility
11. Updates to this Privacy Policy
12. Supplemental California Notice
13. Supplemental European Union and United Kingdom Notice
14. Contact Us

This Privacy Policy covers how we treat certain personal data that we gather from you or other sources when you access or use our Services. “Personal data” means any information relating to an identified or identifiable individual and also includes information referred to as “personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules, or regulations.

This Privacy Policy does not cover the privacy practices of third parties that we do not control, even if we link to these websites or services.

We collect personal data about you from the following categories of sources:

A. Direct Collection. 

We collect personal data you provide directly to us, such as profile or contact data, account information, payment data, photos, videos and recordings. Below are some examples of how we may directly collect personal data that you provide to us:

• When you create an account or use our interactive tools and Services, we may collect your login credentials, first and last name, title or role, email address, phone number, mailing address, and payment data if applicable
• When you use our KYC service, we may collect your driver’s license, passport, social security number, and documentation confirming your address (e.g., a utility bill)
• When you voluntarily provide information in free-form text boxes through the Services or through responses to forms, surveys or questionnaires, we may collect identifying information that you choose to provide
• When you send us an email, request customer or technical support, or otherwise contact us, we may collect your name, contact information, and other identifying information that you choose to provide
• When you participate in audio and video calls with us as part of sales and account management activities, we may collect photos, videos, and recordings of you and your environment
• When you register to and/or attend an event provided by us or that we may sponsor, we may collect your name and contact information
• When you participate in contests, gifting, and other promotional and marketing activities, we may collect your name, contact information, and mailing address
• When you request information or download resources from us, we may collect your name and contact information

B. Automatic Collection.

When you use the Services, personal data is collected automatically, such as device/IP data, web analytics, and geolocation. Below are some examples of how we may automatically collect personal data:

• Through the use of cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”), our servers recognize your web browser, tell us how and when you visit and use our Services, analyze trends, provide functionality such as form completion, learn about our user base and operate and improve our Services. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. For more information regarding Cookies, please see our Cookie Notice.
• We may also supplement the information we collect from you with information received from third parties. We allow analytics providers to deliver Cookies to collect and store analytics information about your interactions with our Services. We also allow advertising networks to deliver Cookies to collect information about your activities on the Services and other websites to provide you targeted advertising based upon your interests. For more information regarding Cookies, please see our Cookie Notice.
• If you use a location-enabled browser, we may receive information about your coarse location (e.g., city, state, postal code), as applicable
• When you browse our online Services, we collect web log data such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services

C. Information From Other Sources.

We may receive personal data from other sources such as other users of Ontra’s services, third-party providers, publicly available sources, and through connected services. Below are some examples of how we may receive your personal data from other sources:

• Other users of the Services, including individuals at your organization, may provide us with your personal data
• We may receive personal data about you from third-party providers of business information and publicly available sources (like social media platforms)
• We may receive your personal data through a third-party integration that you connect to your account via the Services

In the event that you provide any personal data on behalf of another person or entity in connection with or as part of your use of the Services, you understand that it is your responsibility to obtain all right, permission, authority and consent that may be required under applicable law to provide this personal data to Ontra and allow Ontra to use, handle and share this personal data in the manner set forth in this Privacy Policy or the Terms of Service.

We use personal data for a variety of purposes, including:

Providing, Customizing and Improving the Services

• Creating and managing your account
• Authenticating and managing users
• Processing orders or other transactions; billing and payments
• Providing you with the products, services or information you request
• Meeting or fulfilling the reason you provided the information to us
• Providing support and assistance for the Services
• Improving the Services, including testing, research, internal analytics and product development
• Personalizing the Services, website content and communications
• Measuring interest and engagement in the Services
• Fraud protection, security and debugging

Marketing the Services

• Advertising, marketing, and promoting our products, services, and other offerings
• Promoting and managing in-person and online events, registrations and attendance, including sending related communications to you

Corresponding with You

• Communicating with you about your account, activities on the Services, and other administrative matters such as policy updates
• Responding to communications that we receive from you, contacting you when necessary or requested, and sending you information about Ontra or the Services
• Sending emails and other communications according to your preferences or that display content that we think will interest you

Meeting Legal Requirements and Enforcing Legal Terms

• Fulfilling our legal obligations under applicable law, regulation, court order or other legal process
• Preventing, detecting and investigating security incidents and potentially illegal or prohibited activities
• Protecting the rights, property or safety of you, Ontra or another party
• Enforcing any agreements with you
• Responding to claims that any posting or other content violates third-party rights
• Resolving and/or defending disputes

Processing Information on Behalf of Customers

We may receive and process personal data on behalf of our customers that may contain information about you. Our obligations with respect to the processing of such personal data is covered by a Customer Agreement and not this Privacy Policy. If you have questions or concerns about how such personal data is handled or would like to exercise your rights, you should contact the entity that provided that information to us.

Non-Personal Data

We may create aggregated, de-identified and/or anonymized data from the personal data we collect by removing information that makes the data personally identifiable to a particular user. We may use and disclose such aggregated, de-identified and/or anonymized data for our lawful business purposes, including to analyze, build and improve the Services and promote our business and for such other reasons identified in the Terms of Service, provided that we will not disclose such data in a manner that could identify you. We maintain aggregated, de-identified and/or anonymized data in that form, and will not attempt to reidentify the data, except where required or permitted by applicable law.

We disclose personal data to the following categories of third parties:

Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:

• Hosting, technology and communication vendors and providers
• Security and fraud prevention vendors and consultants
• Support and customer service vendors
• Staff augmentation and contract personnel

Advertising Partners. We do not disclose your personal data to advertise any third party’s products or services within the Services. However, we may share your personal data with our advertising partners to deliver personalized ads on other companies’ sites or mobile apps. These parties help us market our business and services and provide you with other offers that may be of interest to you. They include:

• Ad networks
• Marketing providers

Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:

• Companies that attribute how users found or were referred to the Services
• Companies that help us understand how users interact with the Services

Business Partners. These parties partner with us in offering various services. They include:

• Businesses or advisors that you have a pre-existing relationship with and with whom you elect to share or provide access to certain data held in your Ontra account
• With your permission, companies that we partner with to offer joint promotional offers or opportunities

Parties You Authorize, Access or Authenticate

• You may elect to share or provide access to your Ontra account or certain data held in your Ontra account with businesses or advisors that you have a pre-existing relationship with. In this case, the data shared will be processed in accordance with that third party’s policies, not Ontra’s Privacy Policy.
• You or other Service users may choose to connect other third-party service providers through or in connection with the Services, such as where we offer product integrations to improve your experience on the Services. Doing so may give third-party services access to information you choose to use or share in connection with such third-party services. This Privacy Policy does not cover how third parties use your information. We encourage you to review the privacy policies of third parties before connecting to or using their applications or services to learn more about their privacy and information handling practices.

Other Third Parties

With your permission, we may share your personal data with companies that we partner with to offer joint promotional offers or opportunities, such as product and service discounts.

Legal Obligations

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Business Transfers

Personal data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

In accordance with applicable law, you may have the right to:

Access. You may request more information about the personal data we hold about you and request a copy of such personal data.

Portability. You may ask for a copy of your personal data in a machine-readable format. You may also request that we transmit the data to another controller where technically feasible.

Rectification. If you believe that any personal data we are holding about you is incorrect or incomplete, you may request that we correct or supplement such data.

Erasure. You may request that we erase personal data we hold about you from our systems.

Opt Out of or Restrict Certain Processing. You may request that we restrict or stop certain processing of your data, including for purposes of targeted advertising.

To opt out of our processing of personal data for targeted advertising purposes, please select the “Do Not Sell or Share My Personal Information” or de-select targeted advertising cookies in your preferences here.

We also comply with the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based on a consumer’s online behavior across different websites and properties.

To make choices about Interest-Based Ads from participating third parties, including to opt out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt-out pages, which are located at https://www.networkadvertising.org/choices/ or www.aboutads.info/choices. Users in the European Union should visit the European Interactive Digital Advertising Alliance’s user information website https://www.youronlinechoices.eu/.

File a Complaint. You have the right to lodge a complaint about Ontra’s practices with respect to your personal data with the supervisory or regulatory authority of your jurisdiction.

Communications. If you no longer want to receive email communications from us, you can unsubscribe using the link in the footer of the email.

Cookies. You may have the ability to set cookie preferences within your browser; however, note that if you disable cookies through your browser, some functionality of the Services may not work.

To explore what cookie settings are available to you or to modify your preferences with respect to cookies, you can access your cookie management settings by clicking here.
Note that cookie preferences are device-specific––if you use Ontra’s services on more than one device, you will need to indicate your cookie preferences on each device.

To find out more information about cookies generally, including information about how to manage and delete cookies, please visit https://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union or United Kingdom, respectively.

Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that, since there is no universally recognized standard for DNT, we do not respond to or honor DNT signals at this time.

Exercising Your Data Rights. To exercise the rights described in this Privacy Policy, please contact us as described below.

We seek to protect personal data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of personal data and how we are processing that data.

You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain personal data for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting personal data, subject to the data deletion rights of various state privacy laws, detailed below.

When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the personal data, why we collected the personal data, and the sensitivity of the personal data. In some cases we retain personal data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information is no longer personal data.

As noted in the Terms of Service, we do not knowingly collect or solicit personal data about children under 18 years of age; if you are a child under the age of 18, please do not attempt to register for or otherwise use the Services or send us any personal data. If we learn we have collected personal data from a child under 18 years of age, we will delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided personal data to us, please contact us as described below.

All information processed by us may be transferred, processed, and stored anywhere in the world, including the United States and other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

This Privacy Policy webpage uses industry-standard technologies. If you wish to print this policy, please do so from your web browser. If you need further assistance regarding the accessibility of this webpage, please contact us as described below.

As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law.

Personal Data Disclosures

For purposes of the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (together, the “CCPA”), we have collected the following categories of personal data, and disclosed the personal data to the following categories of third parties for a business purpose, in the last 12 months:

Under the CCPA, sharing your data for cross-contextual behavioral advertising is considered a “share” of personal information.

We share your personal data for the purposes of cross-contextual behavioral advertising with the following categories of third parties:

We do not sell personal information for monetary or other valuable consideration.

To our knowledge, we do not sell or share the personal data of minors under 18 years of age for any purpose, including cross-contextual behavioral advertising and targeted advertising.

Sensitive Data

To the extent that we collect “sensitive personal information” (as defined in CCPA), sensitive personal information is not used outside of providing products or services; for security, fraud prevention, and ensuring safety of the services; or for short-term transient use.

Non-Discrimination

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of personal data that we receive from you.

Authorized Agents

If you are a California resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

EU and UK Residents

If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Liechtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (together, “GDPR”) with respect to your personal data, as outlined below.

Lawful Bases for Processing

We will only process your personal data if we have a lawful basis for doing so. We may process your personal data to fulfill our contract with you, to pursue our “legitimate interests” or the legitimate interests of others, with your consent, or to comply with our legal obligations, as further described below.

Contractual Necessity: We process the following categories of personal data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such personal data will result in your inability to use some or all portions of the Services that require such data.

• Profile or contact information
• Identifiers
• Payment data
• Device/IP data
• Other personal data you choose to provide

Legitimate Interests: We process the following categories of personal data when we believe it furthers the legitimate interests of us or third parties:

• Profile or contact information
• Identifiers
• Payment Data
• Device/IP data
• Analytics data
• Geolocation Data
• Other personal data you choose to provide
• We may also de-identify or anonymize personal data to further our legitimate interests

Examples of these legitimate interests include:

• Providing, customizing, and improving the Services
• Marketing the Services
• Corresponding with you
• Provision of customer support
• Protecting from fraud or security threats
• Meeting legal requirements and enforcing legal terms
• Completing corporate transactions

Consent: In some cases and where required by law, we may collect or process personal data based on the consent you expressly grant to us at the time we collect such data. When we process personal data based on your consent, it will be expressly indicated to you at the point and time of collection.

Legal Obligations: From time to time we may also need to process personal data to comply with a legal obligation.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through Ontra and its service providers. Your personal data may be collected, transferred to and stored by us in the United States and by our affiliates and third-parties that are based in other countries.When we transfer personal data of individuals in the EEA, Switzerland or UK, we use a variety of legal mechanisms to safeguard the transfer including the European Commission-approved Standard Contractual Clauses, as well as additional safeguards where appropriate.

EU-U.S. Data Privacy Framework

Ontra complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce (collectively, “DPF”).

Ontra has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, including the principles of 1) notice, 2) choice, 3) accountability for onward transfer, 4) security, 5) data integrity and purpose limitation, 6) access, and 7) recourse, enforcement, and liability. Ontra has also certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.

The DPF Principles require that we remain potentially liable if any third party processing personal data on our behalf fails to comply with these DPF Principles (except to the extent we are not responsible for the event giving rise to any alleged damage). Ontra’s compliance with the DPF is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

Please contact us as described below with any questions or concerns relating to our DPF Certification. In compliance with the DPF, Ontra commits to refer unresolved complaints concerning our handling of personal data received in reliance on the DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you. Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means.

If there is any conflict between the terms in this privacy policy and the DPF Principles, the Principles shall govern. To learn more about the DPF program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your personal data or your choices and rights regarding such collection and use, please do not hesitate to contact us at [email protected] or by mail at:

2041 East Street PMB 39, Concord, CA 94520

Individuals in the EU/EEA and UK, as well as data protection supervisory authorities in the EU/EEA and the UK’s Information Commissioner’s Office (“ICO”) may also contact our data protection representatives according to Article 27 GDPR:

EU:
DP-Dock GmbH
Attn.: Ontra
Ballindamm 39
20095 Hamburg
Germany

UK:
DP Data Protection Services UK Ltd.
Attn.: Ontra
16 Great Queen Street
Covent Garden, London, WC2B 5AH
United Kingdom

[email protected]