Privacy policy

  • This privacy policy (“Policy”) describes how the personally identifiable
    information (“Personal Information”) you may provide on the o-s-mtrading.com
    website (“Website” or “Service”) and any of its related products and services
    (collectively, “Services”) is collected, protected and used.
  • It also describes the
    choices available to you regarding our use of your Personal Information and how
    you can access and update this information.
  • This Policy is a legally binding
    agreement between you (“User”, “you” or “your”) and O.S.M (“O.S.M”, “we”, “us” or
    “our”). By accessing and using the Website and Services, you acknowledge that you
    have read, understood, and agree to be bound by the terms of this Agreement.
  • This Policy does not apply to the practices of companies that we do not own or control,
    or to individuals that we do not employ or manage.
  • Automatic collection of information
    When you open the Website, our servers automatically record information that your
    browser sends.
  • This data may include information such as your device’s IP address,
    browser type and version, operating system type and version, language preferences
    or the webpage you were visiting before you came to the Website and Services,
    pages of the Website and Services that you visit, the time spent on those pages,
    information you search for on the Website, access times and dates, and other
    statistics.
  • Information collected automatically is used only to identify potential cases of
    abuse and establish statistical information regarding the usage and traffic of the
    Website and Services. This statistical information is not otherwise aggregated in
    such a way that would identify any particular user of the system.
  • Collection of personal information
    You can access and use the Website and Services without telling us who you are or
    revealing any information by which someone could identify you as a specific,
    identifiable individual.
  • If, however, you wish to use some of the features on the
    Website, you may be asked to provide certain Personal Information (for example,
    your name and e-mail address). We receive and store any information you knowingly
    provide to us when you create an account, make a purchase, or fill any online
    forms on the Website.
  • When required, this information may include the following:
    – Contact information such as email address, address, etc.
    – Geolocation data such as latitude and longitude.
  • Some of the information we collect is directly from you via the Website and
    Services.
  • However, we may also collect Personal Information about you from other
    sources such as public databases and our joint marketing partners.
  • You can choose
    not to provide us with your Personal Information, but then you may not be able to
    take advantage of some of the features on the Website. Users who are uncertain
    about what information is mandatory are welcome to contact us.
  • Use and processing of collected information
    In order to make the Website and Services available to you, or to meet a legal
    obligation, we need to collect and use certain Personal Information.
  • If you do not
    provide the information that we request, we may not be able to provide you with
    the requested products or services. Any of the information we collect from you may
    be used for the following purposes:
    – Create and manage user accounts
    – Deliver products or services
    – Send administrative information
    – Send marketing and promotional communications
    – Respond to inquiries and offer support
    – Request user feedback
    – Improve user experience
    – Deliver targeted advertising
    – Protect from abuse and malicious users
    – Run and operate the Website and Services
    Processing your Personal Information depends on how you interact with the Website
    and Services, where you are located in the world and if one of the following
    applies:
  • (i) you have given your consent for one or more specific purposes; this,
    however, does not apply, whenever the processing of Personal Information is
    subject to California Consumer Privacy Act or European data protection law;
  • (ii) provision of information is necessary for the performance of an agreement with you
    and/or for any pre-contractual obligations thereof;
  • (iii) processing is necessary
    for compliance with a legal obligation to which you are subject;
  • (iv) processing
    is related to a task that is carried out in the public interest or in the exercise
    of official authority vested in us;
  • (v) processing is necessary for the purposes
    of the legitimate interests pursued by us or by a third party.
  • Note that under some legislations we may be allowed to process information until
    you object to such processing (by opting out), without having to rely on consent
    or any other of the following legal bases below. In any case, we will be happy to
    clarify the specific legal basis that applies to the processing, and in particular
    whether the provision of Personal Information is a statutory or contractual
    requirement, or a requirement necessary to enter into a contract.
  • Billing and payments
    We use third party payment processors to assist us in processing your payment
    information securely.
  • Such third party processors’ use of your Personal
    Information is governed by their respective privacy policies which may or may not
    contain privacy protections as protective as this Policy.
  • We suggest that you
    review their respective privacy policies.
  • Disclosure of information
    Depending on the requested Services or as necessary to complete any transaction
    or provide any service you have requested, we may share your information with your
    consent with our trusted third parties that work with us, any other affiliates and
    subsidiaries we rely upon to assist in the operation of the Website and Services
    available to you.
  • We do not share Personal Information with unaffiliated third
    parties.
  • These service providers are not authorized to use or disclose your
    information except as necessary to perform services on our behalf or comply with
    legal requirements. We may share your Personal Information for these purposes only
    with third parties whose privacy policies are consistent with ours or who agree to
    abide by our policies with respect to Personal Information.
  • These third parties
    are given Personal Information they need only in order to perform their designated
    functions, and we do not authorize them to use or disclose Personal Information
    for their own marketing or other purposes.
  • We will disclose any Personal Information we collect, use or receive if required
    or permitted by law, such as to comply with a subpoena, or similar legal process,
    and when we believe in good faith that disclosure is necessary to protect our
    rights, protect your safety or the safety of others, investigate fraud, or respond
    to a government request.
  • In the event we go through a business transition, such as a merger or acquisition
    by another company, or sale of all or a portion of its assets, your user account,
    and Personal Information will likely be among the assets transferred.
  • Retention of information
    We will retain and use your Personal Information for the period necessary to
    comply with our legal obligations, resolve disputes, and enforce our agreements
    unless a longer retention period is required or permitted by law.
  • We may use any
    aggregated data derived from or incorporating your Personal Information after you
    update or delete it, but not in a manner that would identify you personally. Once
    the retention period expires, Personal Information shall be deleted.
  • Therefore,
    the right to access, the right to erasure, the right to rectification and the
    right to data portability cannot be enforced after the expiration of the retention
    period.
  • Transfer of information
    Depending on your location, data transfers may involve transferring and storing
    your information in a country other than your own.
  • You are entitled to learn about
    the legal basis of information transfers to a country outside the European Union
    or to any international organization governed by public international law or set
    up by two or more countries, such as the UN, and about the security measures taken
    by us to safeguard your information.
  • If any such transfer takes place, you can
    find out more by checking the relevant sections of this Policy or inquire with us
    using the information provided in the contact section.
  • The rights of users
    You may exercise certain rights regarding your information processed by us.
  • In particular, you have the right to do the following:
  • (i) you have the right to withdraw consent where you have previously given your consent to the processing of
    your information;
  • (ii) you have the right to object to the processing of your
    information if the processing is carried out on a legal basis other than consent;
  • (iii) you have the right to learn if information is being processed by us, obtain
    disclosure regarding certain aspects of the processing and obtain a copy of the
    information undergoing processing;
  • (iv) you have the right to verify the accuracy
    of your information and ask for it to be updated or corrected;
  • (v) you have the
    right, under certain circumstances, to restrict the processing of your
    information, in which case, we will not process your information for any purpose
  • other than storing it; (vi) you have the right, under certain circumstances, to
    obtain the erasure of your Personal Information from us;
  • (vii) you have the right
    to receive your information in a structured, commonly used and machine readable
    format and, if technically feasible, to have it transmitted to another controller
    without any hindrance.
  • This provision is applicable provided that your information
    is processed by automated means and that the processing is based on your consent,
    on a contract which you are part of or on pre-contractual obligations thereof.
  • The right to object to processing
    Where Personal Information is processed for the public interest, in the exercise
    of an official authority vested in us or for the purposes of the legitimate
    interests pursued by us, you may object to such processing by providing a ground
    related to your particular situation to justify the objection.
  • You must know that,
    however, should your Personal Information be processed for direct marketing
    purposes, you can object to that processing at any time without providing any
    justification.
  • To learn, whether we are processing Personal Information for direct
    marketing purposes, you may refer to the relevant sections of this document.
  • Data protection rights under GDPR
    If you are a resident of the European Economic Area (EEA), you have certain data
    protection rights and O.S.M aims to take reasonable steps to allow you to correct,
    amend, delete, or limit the use of your Personal Information.
  • If you wish to be
    informed what Personal Information we hold about you and if you want it to be
    removed from our systems, please contact us.
  • In certain circumstances, you have
    the following data protection rights:
  • – You have the right to request access to your Personal Information that we store
    and have the ability to access your Personal Information.
  • – You have the right to request that we correct any Personal Information you
    believe is inaccurate. You also have the right to request us to complete the
    Personal Information you believe is incomplete.
  • – You have the right to request the erase your Personal Information under certain
    conditions of this Policy.
  • – You have the right to object to our processing of your Personal Information.
  • – You have the right to seek restrictions on the processing of your Personal
    Information. When you restrict the processing of your Personal Information, we may
    store it but will not process it further.
  • – You have the right to be provided with a copy of the information we have on you
    in a structured, machine-readable and commonly used format.
  • – You also have the right to withdraw your consent at any time where O.S.M relied
    on your consent to process your Personal Information.
    You have the right to complain to a Data Protection Authority about our collection
    and use of your Personal Information. For more information, please contact your
    local data protection authority in the European Economic Area (EEA).
  • California privacy rights
    In addition to the rights as explained in this Policy, California residents who
    provide Personal Information (as defined in the statute) to obtain products or
    services for personal, family, or household use are entitled to request and obtain
    from us, once a calendar year, information about the Personal Information
  • we shared, if any, with other businesses for marketing uses. If applicable, this
    information would include the categories of Personal Information and the names and
    addresses of those businesses with which we shared such personal information for
    the immediately prior calendar year (e.g., requests made in the current year will
    receive information about the prior year).
  • To obtain this information please
    contact us.
    How to exercise these rights
    Any requests to exercise your rights can be directed to O.S.M through the contact
    details provided in this document. Please note that we may ask you to verify your
    identity before responding to such requests.
  • Your request must provide sufficient
    information that allows us to verify that you are the person you are claiming to
    be or that you are the authorized representative of such person.
  • You must include
    sufficient details to allow us to properly understand the request and respond to it.
  • We cannot respond to your request or provide you with Personal Information
    unless we first verify your identity or authority to make such a request and
    confirm that the Personal Information relates to you.
  • Privacy of children
    We do not knowingly collect any Personal Information from children under the age
    of 18. If you are under the age of 18, please do not submit any Personal
    Information through the Website and Services.
  • We encourage parents and legal
    guardians to monitor their children’s Internet usage and to help enforce this
    Policy by instructing their children never to provide Personal Information through
    the Website and Services without their permission.
  • If you have reason to believe
    that a child under the age of 18 has provided Personal Information to us through
    the Website and Services, please contact us.
  • You must also be at least 16 years of
    age to consent to the processing of your Personal Information in your country (in
    some countries we may allow your parent or guardian to do so on your behalf).
  • Do Not Track signals
    Some browsers incorporate a Do Not Track feature that signals to websites you
    visit that you do not want to have your online activity tracked. Tracking is not
    the same as using or collecting information in connection with a website.
  • For these purposes, tracking refers to collecting personally identifiable information
    from consumers who use or visit a website or online service as they move across
    different websites over time. How
  • browsers communicate the Do Not Track signal is
    not yet uniform.
  • As a result, the Website and Services are not yet set up to
    interpret or respond to Do Not Track signals communicated by your browser. Even
    so, as described in more detail throughout this Policy, we limit our use and
    collection of your personal information.
    Advertisements
    We may permit certain third party companies to help us tailor advertising that
  • we think may be of interest to users and to collect and use other data about user
    activities on the Website. These companies may deliver ads that might place cookies and otherwise track user behavior.
  • Email marketing
    We offer electronic newsletters to which you may voluntarily subscribe at any
    time.
  • We are committed to keeping your e-mail address confidential and will not
    disclose your email address to any third parties except as allowed in the
    information use and processing section or for the purposes of utilizing a third
    party provider to send such emails.
  • We will maintain the information sent via email in accordance with applicable laws and regulations.
    In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state
    who the e-mail is from and provide clear information on how to contact the sender.
  • You may choose to stop receiving our newsletter or marketing emails by following
    the unsubscribe instructions included in these emails or by contacting us.
    However, you will continue to receive essential transactional emails.
    Links to other resources
    The Website and Services contain links to other resources that are not owned or
    controlled by us.
  • Please be aware that we are not responsible for the privacy
    practices of such other resources or third parties.
  • We encourage you to be aware
    when you leave the Website and Services and to read the privacy statements of each
    and every resource that may collect Personal Information.
  • Information security
    We secure information you provide on computer servers in a controlled, secure
    environment, protected from unauthorized access, use, or disclosure.
  • We maintain reasonable administrative, technical, and physical safeguards in an effort to
    protect against unauthorized access, use, modification, and disclosure of Personal
    Information in its control and custody.
  • However, no data transmission over the
    Internet or wireless network can be guaranteed.
  • Therefore, while we strive to
    protect your Personal Information, you acknowledge that
  • (i) there are security and
    privacy limitations of the Internet which are beyond our control;
  • (ii) the security, integrity, and privacy of any and all information and data exchanged
    between you and the Website and Services cannot be guaranteed; and
  • (iii) any such
    information and data may be viewed or tampered with in transit by a third party,
    despite best efforts.
    Data breach
    In the event we become aware that the security of the Website and Services has
    been compromised or users Personal Information has been disclosed to unrelated
    third parties as a result of external activity, including, but not limited to,
    security attacks or fraud, we reserve the right to take reasonably appropriate
    measures, including, but not limited to, investigation and reporting, as well as
    notification to and cooperation with law enforcement authorities.
  • In the event of
    a data breach, we will make reasonable efforts to notify affected individuals if
    we believe that there is a reasonable risk of harm to the user as a result of the
    breach or if notice is otherwise required by law.
  • When we do, we will post a
    notice on the Website, send you an email.
    Changes and amendments
    We reserve the right to modify this Policy or its terms relating to the Website
    and Services from time to time in our discretion and will notify you of any
    material changes to the way in which we treat Personal Information.
  • When we do, we
    will revise the updated date at the bottom of this page.
  • We may also provide
    notice to you in other ways in our discretion, such as through contact information
    you have provided.
  • Any updated version of this Policy will be effective
    immediately upon the posting of the revised Policy unless otherwise specified.
  • Your continued use of the Website and Services after the effective date of the
    revised Policy (or such other act specified at that time) will constitute your
    consent to those changes.
  • However, we will not, without your consent, use your
    Personal Information in a manner materially different than what was stated at the
    time your Personal Information was collected.
    Acceptance of this policy
    You acknowledge that you have read this Policy and agree to all its terms and
    conditions.
  • By accessing and using the Website and Services you agree to be bound
    by this Policy.
  • If you do not agree to abide by the terms of this Policy, you are
    not authorized to access or use the Website and Services.
  • Contacting us
    If you would like to contact us to understand more about this Policy or wish to
    contact us concerning any matter relating to individual rights and your Personal
    Information, you may do so via the contact form or send an email to info@o-smtrading.com
    This document was last updated on February 2, 2021

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