3. TRANSPARENCY/NOTICE—TYPES of Personal Information We Collect and How We Use It
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with ONEMT and the requirements of applicable law. Some of the ways that ONEMT may collect Personal Information include:
· You may provide Personal Information directly to ONEMT through interacting with the Services, participating in surveys, during events, such as sweepstakes, and requesting Services, or information.
· As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
3.1 Types of Personal Information We Collect
ONEMT collects Personal Information regarding its current, prospective, and former customers, users, visitors, guests, and Employees (collectively “Individuals”).
· Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an account with ONEMT, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
o Communications with Us. We may collect Personal Information from you, such as email address, phone number, or mailing address when you choose to request information about our Services, to request to receive customer or technical support, or otherwise to communicate with us.
o Surveys. From time to time, we may contact you to participate in online and/or offline surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our Services and in any manner consistent with the policies provided herein.
o Posting in the Services. ONEMT may offer publicly accessible Services, such as pages, blogs, private messages, or community forums. You should be aware that, when you disclose information about yourself in ONEMT’s Services, the Services will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Services, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
o Registration for Sweepstakes or Contests. Occasionally, ONEMT may run sweepstakes and contests. We ask those who enter in the sweepstakes or contests to provide contact information (e.g., an e-mail address). If you participate in a sweepstakes or contest, your contact information may be used to reach you about the sweepstakes or contest, and for other promotional, marketing and business purposes. All sweepstakes/contests entry forms will provide a way for participants to opt out of any communications that are not related to awarding prizes.
o Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services, such as preferences.
· Information Submitted Via Services. You agree that ONEMT is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. ONEMT will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
· Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, if you access our Services through a Third-Party application, such as Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, “App Stores”) or Social Networking Sites (“SNS”), such as Facebook, we may collect information about you from that Third-Party application that you have made public via your privacy settings. Information we collect through App Stores or SNS accounts may include your name, your SNS user identification number, your SNS user name, location, sex, birth date, email, profile picture, and your contacts on the SNS. This supplemental information allows us to verify information that you have provided to ONEMT and to enhance our ability to provide you with information about our business, products, and Services.
3.2 How ONEMT Uses Your Information
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
· To Provide Products, Services, or Information Requested. ONEMT may use information about you to fulfill requests for products, Services, or information; including information about potential or future Services, including to:
o Generally manage Individual information and accounts;
o Respond to questions, comments, and other requests;
o Provide access to certain areas, functionalities, and features of ONEMT’s Services;
o Contact you to answer requests for customer support or technical support;
o Allow you to register for events.
· Administrative Purposes. ONEMT may use Personal Information about you for its administrative purposes, including to:
o Measure interest in ONEMT’s Services;
o Develop new products and Services;
o Ensure internal quality control;
o Verify Individual identity;
o Communicate about Individual accounts and activities on ONEMT’s Services and systems, and, in ONEMT’s discretion, changes to any ONEMT policy;
o Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
o Process payment for products or services purchased;
o Process applications and transactions;
o Prevent potentially prohibited or illegal activities;
o Enforce our Terms.
· Marketing ONEMT Products and Services. ONEMT may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content, product, or Services. ONEMT may provide you with these materials by message, phone, postal mail, facsimile, email or other communication means, as permitted by applicable law. Such uses include:
o To tailor content, advertisements, and offers;
o To notify you about offers, products, and services that may be of interest to you;
o To provide Services to you and/or a Third-Party;
o For other purposes disclosed at the time that Individuals provide Personal Information; or
o Otherwise with your consent.
You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described in Section 6 below.
· Research and Development. ONEMT may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, ONEMT may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
· Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third-Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on ONEMT’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 6 below.
· Anonymous and Aggregated Information Use. ONEMT may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access ONEMT’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and ONEMT may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within ONEMT and with Third-Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
· Sharing Content with Friends or Colleagues. ONEMT’s Services may offer various tools and functionalities. For example, ONEMT allows you to provide information about your friends through our referral services, such as “Tell a Friend.” Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by ONEMT or any other Third-Parties for any other purpose.
· Other Uses. ONEMT may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
3.3 Cookies, Mobile advertising identifiers, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
We, as well as Third-Parties that provide content, advertising, or other functionality on our Services, may use mobile advertising identifiers, cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a "device") that allow us to record certain pieces of information whenever you visit or interact with our Services, and to recognize you across devices.
· Mobile Advertising Identifiers. Mobile advertising IDs are identifiers used by mobile operating systems (Apple and/or Android) and made available to advertising providers to gather metrics on mobile apps (Apple’s IDFA or Google’s AAID) to help advertisers provide ads that may be more relevant to your interests. Third-Party advertisers and advertising networks may use advertising identifiers collected from the Services to deliver advertisements they believe are relevant to you in other Third-Party apps.
· Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
· Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
Analytics. We may also use Google Analytics, Google Analytics Demographics and Interest Reporting, and Google Analytics for Firebase including Crashlytics and Fabric Data Processing, such as “Fabric Answers,” “Fabric Crashlytics,” or “Fabric Beta” provided by Google to collect information regarding visitor behavior and visitor demographics on some of our Services, to collect information regarding all or some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. For more information about Google Analytics for Firebase, please visit https://firebase.google.com/docs/analytics/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout. Our uses of such Technologies fall into the following general categories:
· Advertising or Targeting Related. We may use ONEMT or Third-Party cookies and web beacons to deliver content, including advertisements relevant to your interests, in our Services or on Third-Party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt out of the Technologies we employ in our Services, you may do so by blocking, deleting, or disabling them as your browser or device permits.
3.4 Third-Party Websites, Social Media Platforms, and Software Development Kits
The Services may contain links to other websites and other websites may reference or link to our Services. These other domains and websites are not controlled by us, and ONEMT does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every 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. Visiting these other websites or applications is at your own risk.
ONEMT’s Services may include community forums or private messaging features. We use Third-Party software development kits (“SDKs”), such as the adjust GmbH SDK, the AppsFlyer SDK, and the Fabric SDK, as part of the functionality of our Services. Third-Party SDKs may allow Third Parties including advertisers to collect your Personal Information to provide content that is more relevant to you. You may opt out of tracking by Adjust by going to https://www.adjust.com/opt-out/. You may opt out of tracking by AppsFlyer by going to https://www.appsflyer.com/optout. You may opt out of tracking by Fabric by going to http://tools.google.com/dlpage/gaoptout.
3.5 Third-Party Payment Processing
We may sell virtual items or merchandise through our Services. When you make purchases through the Services, we process your payments through a Third-Party application, including the App store and SNS. The Third-Party application may collect certain financial information from you to process a payment on behalf of ONEMT, including your name, email address, address, and/or other information.
4. Human Resources Data
ONEMT collects Personal Information from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a Curriculum Vitae or application form, language abilities, contact information of a Third-Party in case of an emergency, or contact information of a beneficiary under any insurance policy. We may also collect Sensitive Human Resources Data, such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information, such as race, which helps us achieve our diversity goals.
We acquire, hold, use, and Process Human Resources Data for a variety of business purposes including:
· Workflow management, including assigning, managing and administering projects;
· Human Resources administration and communication;
· Payroll and the provision of benefits;
· Compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;
· Job grading activities;
· Performance and employee development management;
· Organizational development and succession planning;
· Benefits and personnel administration;
· Absence management;
· Helpdesk and IT support services;
· Regulatory compliance;
· Internal and/or external or governmental compliance investigations;
· Internal or external audits;
· Litigation evaluation, prosecution, and defense;
· Diversity and inclusion initiatives;
· Restructuring and relocation;
· Emergency contacts and services;
· Employee safety;
· Compliance with statutory requirements;
· Processing of Employee expenses and travel charges; and
· Acquisitions, divestitures, and integrations.
5. Onward Transfer—ONEMT May Disclose Your Information
5.1 Information We Share
· We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Services.
· Business Partners. ONEMT may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. ONEMT may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with ONEMT. ONEMT requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which ONEMT provided them.
· Displaying to Other Users. The content you post to the Services may be displayed in the Services. Other users of the Services may be able to see some information about you, such as your name if you submit a review. We are not responsible for privacy practices of the other users who will view and use the posted information.
· Marketing – Interest-Based Advertising and Third-Party Marketing. Through our Services, ONEMT may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-ONEMT related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.” We may allow access to other data collected by the Services to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt out of such sharing at no cost by following the instructions in Section 6 below.
· Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, and other account information and content, if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours, ours or others’ rights, property, or safety; (iv) to enforce ONEMT policies or contracts; (v) to collect amounts owed to ONEMT; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
5.2 Data Transfers
All Personal Information collected via or by ONEMT may be stored anywhere in the world, including but not limited to, in the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to ONEMT, you consent to the storage of your Personal Information in these locations.
6. Opt-Out (RIGHT TO RESTRICT PROCESSING)
You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to ONEMT’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting email@example.com. Even if you opt out, we may still collect and use non-Personal Information regarding your activities in our Services and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
6.2 Email and Telephone Communications
We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
6.3 Mobile devices
ONEMT may occasionally send you push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. ONEMT may also collect location-based information if you use our mobile applications. You may opt out of this collection by changing the settings on your mobile device.
You can change or disable the mobile advertising identifiers in your mobile device or limit advertising tracking through your mobile device operating system’s privacy settings. For more information on how to change the advertising identifier privacy settings on your device, please visit http://www.networkadvertising.org/mobile-choice or http://youradchoices.com/appchoices.
6.4 Human Resources Data
With regard to Personal Information that ONEMT receives in connection with the employment relationship, ONEMT will use such Personal Information only for employment-related purposes as more fully described above. If ONEMT intends to use this Personal Information for any other purpose, ONEMT will notify the Individual and provide an opportunity to opt out of such uses.
6.5 “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
6.6 Cookies and Interest-Based Advertising
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile advertisements via their device settings.
The online advertising industry also provides websites from which you may opt out of receiving targeted advertisements from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here.
7. Rights of Access, Rectification, Erasure, and Restriction
Although ONEMT makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which ONEMT is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If ONEMT determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, ONEMT will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
8. Data Retention
9. Security of Your Information
By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice within the Services or sending an e-mail to you. You may have a legal right to receive this notice in writing.
10. International Users
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and People’s Republic of China and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
Some countries (including those in the European Union) have laws that require agreements to be governed by the local laws of the consumer's country or require that their substantive laws, including privacy laws, apply. This section does not override those laws.
11. Children’s Privacy
The Services are not directed to children under 13, and ONEMT does not knowingly collect Personally Identifiable Information from children under 13. In addition, you are not permitted to use our Services if you do not meet the minimum age requirement applicable to our Services in your jurisdiction. If you learn that your child has provided us with Personal Information without your consent, you may alert us at firstname.lastname@example.org. If we learn that we have collected any Personal Information from children under 13 (and in jurisdictions under the age of 16 in the European Union), we will promptly take steps to delete such information and terminate the child’s account.
12. Redress/Compliance and Accountability
13. Other Rights and Important Information
· New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, ONEMT will endeavor to comply with the law or contract.
The following capitalized terms shall have the meanings herein as set forth below.
· “Agent” means any Third-Party that Processes Personal Information pursuant to the instructions of, and solely for, ONEMT or to which ONEMT discloses Personal Information for use on its behalf.
· “Employee” refers to any current, temporary, permanent, prospective or former employee, director, contractor, worker, or retiree of ONEMT or its subsidiaries worldwide.
· “Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
· “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
· “Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.
· “Third-Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, ONEMT or ONEMT’s Agents.
15. Revision history
Title (Effective Date)