Privacy Policy

Last Updated: 15th October, 2022

Summary of Privacy Policy

Onion Technology Systems Ltd., a Delaware limited liability company (the “Company” or “we” or “us”), is committed to protecting the privacy of your data. This Privacy Policy (the “Policy”) applies to those who visit the websites owned and operated by the Company and/or use the Company’s products and services (collectively, the “Services”). For purposes of this Policy, personal data shall mean any information relating to an identified or identifiable natural person. For example, this might be by reference to an identifier such as a name, ID number, location data or online identifier.

This Privacy Policy describes how the Company collects, uses, shares and secures the personal data of the Users of the Services (the “User(s)” or “you” or “yours”, as applicable). It also describes the User’s choices regarding the use, access and correction of the User’s personal data. The capitalized terms used in this Policy but not defined herein shall have the same meaning assigned to them in Company’s Terms of Service (the “Terms”).

Data Transfer

The Company is a global company based in the United States. As such, we may transfer and access such personal information from around the world, including from other countries. In sharing your personal data, we will rely on legal measures to share your personal information outside the EEA and Switzerland. Therefore, if you are visiting the Services from the EEA or other regions with laws governing data collection and use, please note that by providing this personal information, you acknowledge that your personal information may be transferred to the United States and other jurisdictions in which we operate.

Information collection and use

The Company gathers two types of information: (1) personally identifiable information that is supplied voluntarily upon registration for Services, ordering products from Services, or when you enter certain other areas of the Company’s websites and (2) aggregate tracking and site usage information that is gathered automatically when you use the Services. It is Company’s Policy to use the personally identifiable information acquired at Company’s Websites for internal business uses only and to provide content, products and Services. In addition, the Company operates and maintains various online security measures to safeguard and keep personal data private.

Information That You Provide to Us

When you register for an account to access or utilize the Services (an “Account”), we ask for and may collect personal information about you such as your name or your Company, address, phone number, email address, credit card or other payment method information (collectively, an “Account Information”). By providing us with Account Information, you represent that you are the owner of such personal data or otherwise have the requisite consent to provide it to us.

The Company only collects “sensitive” personal information when you voluntarily provide us with this information or where such information is required or permitted to be collected by law or professional standards. Sensitive information includes personal information regarding a person’s race, ethnicity, political, philosophical, religious or similar beliefs, trade union membership, physical or mental health, sexual life, sexual orientation, or criminal record.

Please use your discretion when providing sensitive information to the Company, and under any circumstances, do not provide sensitive information to the Company unless you thereby consent to the Company’s use of that information for its legitimate business purposes and consent to the transfer and storage of such information to and in the Company’s databases. If you have any questions about whether the provision of sensitive information to the Company is, or maybe, necessary or appropriate for particular purposes, please get in touch with us at hi@useonion.com.

Third-Party Channels

We may provide an option to access or register for the Services through your user name and passwords for certain services provided by third parties (each, a “Third Party Channels”), such as through your Microsoft or Google account. By authorizing us to connect with a Third Party Channels, you authorize the Company to access and store the information that the Third Party Channels makes available to us and to use and disclose it in accordance with this Policy. You are responsible for checking your privacy settings for such Third Party Channels (please review the terms of use and privacy policy of such Third Party Channels) to control what information is available to us.

Automatic collection of personal information

In some instances, the Company and its service providers use cookies, web beacons and other technologies to automatically collect certain types of information when you use the Services and through emails that we may exchange. This information allows us to customize your online experience; improve the performance, usability and effectiveness of the Services; advertise and market our services; measure the effectiveness of our marketing activities; and generate and analyze statistics about your use of the Services.

IP addresses

An IP address is a number assigned to your computer or internet-enabled device whenever you access the internet. It allows computers and servers to recognize and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to maintain and improve the Services and to generate and analyze statistics about the Services and your use of the Services.

Other Browser Data

We may also collect your browser information (e.g., apps you use, duration of use, etc.), Browser code and signature, Browser and OS version, Extensions and version numbers that are installed, a list of open URLs, User account information (name, email, license type), hardware information, and other browser configurations.

Cookies

The purpose of cookies is to collect your computer's standard internet log and visitor behaviour information. This information is then used to track visitor use of the website and to create statistical reports on website activity. You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, please note in a few cases, some the Services features may not function because of this.

By accessing or using the services or entering your login details to access areas reserved for registered users, you agree that we, or a third party acting on our behalf, can place these cookies on your computer or internet-enabled device.

Usage analytics

We use several third party usage analytics tools, including Google Analytics. More information about how the Company uses Google Analytics can be found here. To give website visitors more choices on how Google Analytics collects their data, Google has developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. However, the Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the Online Services or other web analytics services.

Web beacons

Web beacons are small images on web pages that gather certain information, such as an IP address, the time the content was viewed, a browser type, and whether the server has previously set cookies. We only use web beacons per applicable laws. The Company or its service providers may use web beacons to track the effectiveness of third-party websites that provide us with.

How we use the information that we collect

Legal Basis for Processing (EEA only)

We may use the information we collect about you (including personal information, to the extent applicable) for a variety of purposes, including to:

  • Provide, operate, maintain, improve, and promote the Services.
  • Enable you to access and use the Services.
  • Process and complete transactions.
  • Provide customer service and support and send you related notices.
  • Send promotional communications.
  • Process and deliver contest or sweepstakes entries and rewards.
  • Monitor and analyze trends, usage, and activities in connection with the Services and for marketing or advertising purposes.
  • Monitor and assess compliance with our policies and standards.
  • For other purposes for which we obtain your consent.

Concerning newsletters, updates and other general communications, we will – where legally required – only provide you with such information if you have opted in. You can opt-out of receiving such communications at any time.

Permitted Purposes

Suppose you are an individual from the European Economic Area (EEA). In that case, we use your personal data, and we may process your personal data on one or more of the following legal grounds:

  • Because processing is necessary to perform a contract with you, such as to deliver the Services.
  • To comply with our legal obligations.
  • Because processing is necessary for our legitimate interest or those of any third-party recipients that receive your personal data, provided that such interests are not overridden by your interests or fundamental rights and freedoms.

We may also process your data based on your consent, where you have expressly given that to us.

How we share the information that we collect

We share information, including personal information, with our third-party service providers that we use to provide hosting for and maintenance of the Services. These third-party service providers may have access to or process your personal information to provide these services for us. We do not permit our third-party service providers to use the personal information we share with them for their marketing purposes or for any other purpose than in connection with the services they provide.

We may share your personal data with courts, law enforcement authorities, regulators, attorneys, or other parties where it is reasonably necessary to establish, exercise, or defend a legal or equitable claim or for a confidential alternative dispute resolution process. We may also share such information if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms and conditions, or as otherwise required by law.

We may share your personal data with any third party to whom we assign or novate any of our rights or obligations, or that acquires all or substantially all of our business, stock or assets, or with whom we merge.

We may also instruct service providers to process personal data for the Permitted Purposes on our behalf and per our instructions only. We will retain control over and remain fully responsible for your personal data. We will use appropriate safeguards as required by the applicable law to ensure the integrity and security of your personal data when engaging such service providers.

We may also use aggregated personal data and statistics to monitor website usage to help us develop our website and services. 

We will otherwise only disclose your personal data when you direct us or give us permission to do so, when we are required by applicable law or regulations or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.

Where we rely on your consent to process the personal information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.

Suppose we ask you to provide personal information to comply with a legal requirement or to perform a contract with you. In that case, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). 

Similarly, if we collect and use your personal information in reliance on our (or a third party's) legitimate interests not already described in this Notice, in that case, we will inform you at the appropriate time what those legitimate interests are.

If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at hi@useonion.com.

Security precautions

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once received. If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach per applicable law. Please note, however, that no security precautions are foolproof, and we disclaim all liability for security breaches.

How long we retain your personal information

We will retain your personal information for as long as is needed to fulfil the purposes outlined in this Policy unless a more extended retention period is required or permitted by law (such as tax, accounting or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. For personal information that we process on behalf of our Users, we will retain such personal information per the terms of our agreement with them, subject to applicable law.

Your privacy rights

Upon request, we will provide you with information about whether we hold or process any of your personal information on behalf of a third party. To request this information, please get in touch with us at hi@useonion.com. Users may update or change their Account Information by editing their profile within the Services. To request to have personal information maintained by us returned to you or removed, please hi@useonion.com. Requests to access, change, or remove your information will be handled within thirty (30) days; provided that, notwithstanding such request, this information may be retained for as long as you maintain an account for the Services or as needed to provide you with Services, comply with our legal obligations, resolve disputes and enforce our agreements. Upon receipt of a request from one of our Users for us to remove the data, we will respond to their request within thirty (30) days. We will retain personal information that we store and process on behalf of our Users for as long as needed to provide the Services to our Users. We will keep and use this personal information to comply with our legal obligations, resolve disputes, and enforce our agreements.

Other websites

Our website contains links to other websites. This privacy policy only applies to this website, so you should read their privacy policies when you link to other websites.

Delaware privacy rights

We will not share any Personal Data with third parties for their direct marketing purposes to the extent prohibited by Delaware law. If our practices change, we will comply with applicable laws and notify you in advance.

Contacting us

Please get in touch with us if you have any questions about our privacy policy or the information we hold about you at hi@useonion.com.

Changes to the Policy

If the Company makes any material changes or amendments to the Policy, the Company will post a notice on this website. Your continued use of the Services constitutes your acceptance of all such modifications and revisions. Your sole remedy is to cease using the Services.

Any questions regarding the Policy, personal data collection, and other practices should be directed to hi@useonion.com.