Privacy Policy

Last updated: March 15, 2022

 

This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

 

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

 

Interpretation and Definitions

 

Interpretation

 

Words with initial capitalization have meanings defined under the following conditions. These definitions shall have the same meaning regardless of whether they appear in singular or in plural.

 

Definitions

 

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.

• Affiliate means an entity that controls, is controlled by, or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

• Application means the software program provided by the Company downloaded by You on any electronic device, named OnSoCo.

• Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of Consumers’ personal information, that does business in the State of California.

• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to OnSoCo, 3360 Post Office Rd Unit 7957, Woodbridge, VA 22195-8296.
  For the purpose of the GDPR, the Company is the Data Controller.

• Consumer, for the purpose of the CCPA, means a natural person who is a California resident.

• Country refers to Virginia, United States.

• Data Controller, for the purposes of the GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

• Device means any device that can access the Service such as a computer, a cellphone, or a digital tablet.

• Do Not Track (DNT) is a concept promoted by U.S. regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

• Facebook Fan Page is a public profile named OnSoCo created by the Company on Facebook, accessible from http://facebook.com/onsoco

• Personal Data is any information that relates to an identified or identifiable individual.

• Sale, for the purpose of the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a Consumer’s personal information to another business or a third party for monetary or other valuable consideration.

• Service refers to the Application and any related websites operated by the Company that link to this Privacy Policy.

• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

• Third-Party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.

• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR, You may be referred to as the Data Subject or the User.

 

Collecting and Using Your Personal Data

 

Types of Data Collected

 

Personal Data

 

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address

• First name and last name (if provided)

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User-Generated Content (Photos and Videos)

 

The Service allows You to upload content such as photos and videos as part of contest participation and other features. This content may be public within the Service depending on how it is shared and where it is posted.

 

Usage Data

 

Usage Data is collected automatically when using the Service.

 

Usage Data may include information such as Your Device’s Internet Protocol address (e.g., IP address), device identifiers, browser type (for website use), operating system, the time and date of Your use, the time spent within the Service, and other diagnostic data.

 

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, and other diagnostic data.

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Information from Third-Party Social Media Services

 

The Company allows You to create an account and log in to use the Service through Third-Party Social Media Services such as:

• Google

• Facebook

• Twitter/X (if enabled)

 

If You decide to register through or otherwise grant Us access to a Third-Party Social Media Service, We may collect Personal Data that is already associated with Your Third-Party Social Media Service’s account, such as Your name and email address, subject to the settings and permissions You choose with that provider.

 

Information Collected while Using the Application (Device Permissions)

 

To provide features of the Application, We may request access (with Your permission) to:

• Camera and photo library (to allow You to upload or create Content, such as contest entries)

 

We do not access Your contacts list.

 

We do not collect precise GPS location. We may derive approximate location from IP address or through advertising partners for purposes such as fraud prevention, analytics, and advertising measurement.

 

You can enable or disable permissions at any time through Your Device settings.

 

Use of Your Personal Data

 

The Company may use Personal Data for the following purposes:

• To provide and maintain the Service, including to monitor usage and ensure the Service functions as intended.

• To manage Your Account, including registration and authentication.

• For the performance of a contract, such as providing features You request or services You purchase through the Service.

• To contact You, including by email or push notifications regarding updates, security, and important service communications.

• To manage Your requests, including customer support and issue resolution.

• To deliver and measure advertising, including showing advertisements in the Service and measuring their effectiveness.

• For analytics and improvements, such as identifying usage trends and improving features, safety, and performance.

• For business transfers, such as in connection with a merger, acquisition, or asset sale.

• For security and integrity, including detecting and preventing fraud, abuse, or violations of policies.

 

Sharing of Your Personal Data

 

We may share Your personal information in the following situations:

• With Service Providers: We may share information with Service Providers to facilitate the Service, support analytics, provide hosting/storage, deliver ads, measure ad performance, and provide customer support.

• For business transfers: We may share or transfer information in connection with a merger, sale of Company assets, financing, or acquisition.

• With Affiliates: We may share information with Affiliates who must honor this Privacy Policy.

• With business partners: We may share information with business partners to provide features, services, or Promotions where applicable.

• With other users: When You post Content or interact in public areas of the Service, that information may be viewed by other users. If You choose to interact with other users, Your profile information and content may be visible.
  The Company will never ask You to provide payment details, sensitive personal information, or verification documents through direct messages in order to participate in a contest or to use the Service.

• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

 

Retention of Your Personal Data

 

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy, including compliance with legal obligations, resolving disputes, and enforcing legal agreements and policies.

 

Usage Data is generally retained for a shorter period, except when used for security purposes or when legally required.

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Transfer of Your Personal Data

 

Your information may be processed at the Company’s operating offices and in other locations where the parties involved in processing are located. This may involve transferring data to jurisdictions with different data protection laws.

 

We will take reasonable steps to ensure that Your data is treated securely and in accordance with this Privacy Policy.

 

Disclosure of Your Personal Data

 

Business Transactions

 

If the Company is involved in a merger, acquisition, or asset sale, Your Personal Data may be transferred. We will provide notice before Your

Personal Data is transferred and becomes subject to a different Privacy Policy.

 

Law enforcement

 

We may disclose Your Personal Data where required to do so by law or in response to valid requests by public authorities.

 

Other legal requirements

 

We may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation

• Protect and defend the rights or property of the Company

• Prevent or investigate wrongdoing in connection with the Service

• Protect the personal safety of users or the public

• Protect against legal liability

 

Security of Your Personal Data

 

We use commercially reasonable measures designed to protect Your Personal Data. However, no method of transmission or storage is 100% secure, and We cannot guarantee absolute security.

 

Detailed Information on the Processing of Your Personal Data

 

Service Providers may have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for other purposes.

 

Analytics

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We may use third-party Service Providers to monitor and analyze use of the Service.

 

Google Analytics (Website Use)
Google Analytics may be used for our website(s) to measure and report traffic. You can learn more at Google’s Privacy Policy: https://policies.google.com/privacy

 

Firebase (Application Use)
Firebase is an analytics service provided by Google. Firebase may collect device and usage information used for analytics and service operations. More information: https://policies.google.com/technologies/partner-sites

 

Advertising

 

We may use Service Providers to show advertisements in the Service and to measure their performance.

 

AdMob by Google
 

AdMob is provided by Google and may use device identifiers and other information to serve and measure ads. You can learn more about Google’s practices and controls here: https://policies.google.com/privacy

 

Behavioral Remarketing (Website / Third-Party Platforms)

 

We may use remarketing services to advertise to You after You accessed or visited our website(s). These services may use cookies and similar technologies.

 

You may opt out of certain interest-based advertising through:

• NAI: http://www.networkadvertising.org/choices/

• DAA: http://optout.aboutads.info/?c=2&lang=EN

• EDAA: http://www.youronlinechoices.com/

 

Mobile device settings may also allow you to limit ad personalization (iOS/Android).

 

GDPR Privacy

 

Legal Basis for Processing Personal Data under GDPR

 

We may process Personal Data based on: consent, performance of a contract, legal obligations, vital interests, public interests, and legitimate interests.

 

Your Rights under the GDPR

 

You may have rights to access, correct, delete, object to processing, request portability, and withdraw consent. We may ask You to verify

identity before responding.

 

You may complain to a Data Protection Authority in the EEA if applicable.

 

Facebook Fan Page

 

As operator of the Facebook Fan Page, the Company and Facebook may act as Joint Controllers for certain processing. For more information, see Facebook’s policies: https://www.facebook.com/privacy/explanation

 

CCPA Privacy (California Residents)

 

This section supplements the Privacy Policy for California residents.

 

Categories of Personal Information Collected

 

We may collect identifiers (such as email), internet/network activity, and approximate geolocation (derived from IP or advertising partners). We may collect other information you provide when using the Service.

 

Sources of Personal Information

 

We obtain information:

• Directly from You

• Automatically from Your use of the Service

• From Service Providers (analytics and advertising partners)

 

Use of Personal Information

 

We use information for operating the Service, support, analytics, security, fraud prevention, and advertising measurement, as described above.

 

Disclosure of Personal Information

 

We may disclose information to Service Providers and business partners for business purposes such as providing the Service, analytics, and advertising measurement.

 

Sale / Sharing of Personal Information

 

The Company does not sell Your personal information for monetary consideration. However, certain advertising and analytics partners may process information collected through the Service in a manner that may be considered a “sale” or “sharing” of personal information under

California law.

 

California residents may opt out of such processing as described below.

 

Your Rights under the CCPA

 

California residents may have the right to:

• Request disclosure of information collected, used, and shared

• Request deletion (subject to legal exceptions)

• Opt out of certain sales/sharing

• Non-discrimination for exercising rights

 

Exercising Your CCPA Rights

 

To submit a request, contact Us:

• Contact page: https://www.onsoco.com/contact-us

• Email: privacy@onsoco.com

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We may need to verify Your identity before responding. We will respond within the timeframes required by law.

 

Do Not Sell / Share My Personal Information

To opt out of interest-based advertising and potential “sale/sharing” under California law, you may:

• Use your mobile device advertising/privacy settings

• Use industry opt-out tools listed above (NAI/DAA/EDAA)

• Contact us using the methods above

 

“Do Not Track” (CalOPPA)

 

Our Service does not respond to Do Not Track signals. You can enable or disable DNT through your browser settings.

 

Children’s Privacy

 

The Service is intended for users age 13 and older.

 

We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

 

If We rely on consent as a legal basis for processing and Your country requires parental consent for minors, We may require a parent’s consent before collecting or using that information.

 

California Privacy Rights (Shine the Light)

 

California residents with an established business relationship may request information once per year regarding sharing of Personal Data for third parties’ direct marketing purposes. Contact Us using the information below.

 

California Privacy Rights for Minor Users (Removal Requests)

 

California residents under 18 may request removal of content they publicly posted, subject to limitations and legal requirements. Contact Us and include the email address associated with Your Account.

 

Links to Other Websites

 

Our Service may contain links to other websites not operated by Us. We strongly advise You to review the Privacy Policy of every site You visit.

 

Changes to this Privacy Policy

 

We may update this Privacy Policy from time to time. We will notify You of changes by posting the new policy and updating the “Last updated” date.

 

Contact Us

 

If you have any questions about this Privacy Policy, you can contact us:

• By visiting: https://www.onsoco.com/contact-us

• By email: privacy@onsoco.com