Privacy Notice

This Privacy Notice is designed to help you understand how Osmo Technologies Inc. (“Osmo,” “we,” “us,” or our”) collects, uses, and shares your personal information, and to help you understand and exercise your privacy rights.

1. Scope and updates to this privacy notice

This Privacy Notice applies to personal information processed by us, including on our websites and other online or offline offerings. To make this Privacy Notice easier to read, our websites and other offerings are collectively called the “Services.”  

Changes to our Privacy Notice
. We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Services after the new Privacy Notice takes effect.

2. Personal information we collect

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

A.    Personal Information You Provide to Us Directly. We may collect personal information that you provide to us.


·      Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about Osmo or our Services, register for our newsletter, request support, or otherwise communicate with us. 
·      Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey. 
·      Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g.,commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. 
·      Your Notes and Transcriptions.
As part of our services, Osmo users may use the feature to transcribe audio recordings of meetings and conversations. This transcription is executed locally on your device. For users who opt to collaborate with others, Osmo offers cloud storage for these transcriptions.
·      Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
·       Job Applications. We may post job openings and opportunities on our Services. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us. 
·       Google User Data. Osmo uses Google user data solely for the purpose of authenticating users of our Services. We do not access, store, or share any Google user data for any other purposes.

B.     Personal Information Collected Automatically

We may collect personal information automatically when you use our Services.

·      Automatic Collection of Personal Information.
We may collect certain information automatically when you use our Services, 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, location information (including approximate location derived from IP address),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.

·      Cookie Policy (and Other Technologies). We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Services.
o  Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience. 
o  Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

C.     Personal Information Collected from Other Sources

Third-Party Services and Sources.
We may obtain personal information about you from other sources, including through third-party services and organizations.  For example, if you access our Services through a third-party application, we may collect personal information about you from that third-party application that you have made available via your privacy settings. Our customers may upload recordings and other information to our Services, in which case our customers are responsible for providing notice and obtaining consent under applicable laws for us to provide the Services.

Referrals and Sharing Features. Our Services may offer various tools and functionalities that allow you to provide personal information about your friends through our referral service. Our referral services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).

3. How we use your personal information

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A.    Provide Our Services

We use your personal information to fulfill our contract with you and provide you with our Services, such as:

·      Managing your information and accounts;
·      Providing access to certain are
as, functionalities, and features of our Services;
·      Answering requests for customer or technical support;
·      Communicating with you about your account, activities on our Services, and policy changes;
·      Processing applications if you apply for a job we post on our Services; andAllowing you to register for events.

B.    Administrative Purposes 
We use your personal information for various administrative purposes, such as: 

·      Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
·      Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
·      Measuring interest and engagement in our Services;
·      Improving, upgrading, or enhancing our Services;
·      Developing new products and services;
·      Ensuring internal quality control and safety;
·      Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;
·      Debugging to identify and repair errors with our Services;
·      Auditing relating to interactions, transactions, and other compliance activities;
·      Sharing personal information with third parties as needed to provide the Services;
·      Enforcing our agreements and policies;
·      Carrying out analytics; and
·      Carrying out activities that are required to comply with our legal obligations.


C.    Marketing and Advertising our Products and Services We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.  Some of the ways we may market to you include email campaigns, text messages, custom audiences advertising, and“personalized advertising” or “targeted advertising,” including through cross-device tracking. If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.  

D.    With Your Consent 

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent. 

E.    Other Purposes 

We also use your personal information for other purposes as requested by you or as permitted by applicable law. 

·      De-identified and Aggregated Information. We may use personal information to create de-identified and/or aggregated information, such as demographic information, information about how you use the Services, information about the device from which you access our Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use, disclose, and retain such information as permitted by applicable laws including, but not limited to, for research, analysis, analytics, and any other legally permissible purposes.

- Authentication: We use your personal information, including the Google user data, solely for authenticating your account to provide access to our Services.

4. How we disclose your personal information

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A.    Disclosures to Provide our Services The categories of third parties with whom we may share your personal information are described below.  

·      Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Services. This includes service providers and vendors that provide us with IT support, hosting, payment processing, customer service, and related services. 
·      Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services. 
·      Affiliates. We may share your personal information with our corporate affiliates.  
·      Advertising Partners. We may share your personal information with third-party advertisingpartners. These third-party advertising partners may set Technologies and othertracking tools on our Services to collect information regarding your activitiesand your device (e.g., your IP address, cookie identifiers, page(s) visited,location, time of day). These advertising partners may use this information(and similar information collected from other services) for purposes ofdelivering personalized advertisements to you when you visit digital propertieswithin their networks. This practice is commonly referred to as “interest-basedadvertising”, “personalized advertising”, or “targeted advertising.” 

B.    Disclosures to Protect Us or Others We may access,preserve, and disclose any information we store associated with you to externalparties 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 s; or assist with an investigation or prosecution of suspected or actualillegal activity. 

C.    Disclosure in the Event ofMerger, Sale, or Other Asset Transfers If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract. 

5. Your privacy choices and rights

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
·      Email Communications. If you receive an unwanted email from us, you can use the unsubscribelink found at the bottom of the email to opt out of receiving future emails.Note that you will continue to receive transaction-related emails regardingproducts or Services you have requested. We may also send you certainnon-promotional communications regarding us and our Services, and you will notbe able to opt out of those communications (e.g., communications regarding ourServices or updates to our Terms or this Privacy Notice).  
·      “Do Not Track. Do NotTrack (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. 

·      Cookies and Personalized Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly.Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others. 

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.  Please note you must separately opt out in each browser and on each device.  

Your Privacy Rights. In accordance with applicable law, you may have the right to: 
·      Access to and Portability of YourPersonal Information, including: (i) obtaining access to or a copy of your personal information; and (ii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format(also known as the “right of data portability”); 
·      Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information; 
·      Request Deletion of your personal information;  
·      Request Restriction of or Object to our processing of your personal information; and 
·      Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal. 

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

6. International Transfers of Personal Information

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your personal information consistent with the requirements of applicable laws.

If we transfer personal information which originates in theEuropean Economic Area, Switzerland, and/or the United Kingdom to a countrythat has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to supportsuch transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

7. Retention of personal information

If we transfer personal information which originates in theEuropean Economic Area, Switzerland, and/or the United Kingdom to a countrythat has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to supportsuch transfer is the EU Standard Contractual Clauses.

To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

8. Our lawful basis for processing

If your personal information is subject to the EU or UK General Data Protection Regulation, our processing of your personal information may be supported by one of the following lawful bases:

·       Performance of a Contract. We may process your personal information to carry out our contract with you or to take steps at your request prior to entering into a contract.
·       Legitimate Interest. We may process your personal information to further our legitimate interests, but only where our interests are not overridden by your interests or fundamental rights and freedoms.
·       Compliance with Legal Obligations. We may process your personal information to comply with our legal obligations.
·      Consent. In some cases, we may also rely on your consent to process your personal information for a specific purpose.

9. Our lawful basis for processing

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in “Contact Us” below.

10. Children's Information

The Services are not directed to children under 16 (or other age as required by local law), and we do not knowingly collect personal information from children. 

If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.

11. Other provisions

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

Supervisory Authority. If your personal information is subject to the applicable data protection laws of  theEuropean Economic Area, Switzerland, or the United Kingdom,, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates applicable law.

·      EEA Data Protection Authorities (DPAs)
·      Swiss Federal Data Protection and Information Commissioner (FDPIC)
·      UK Information Commissioner’s Office (ICO)

12. Contact Us

Osmo is the controller of the personal information we process under this Privacy Notice.  

If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at: 

Osmo Technologies, Inc.
team@getosmo.com