Olasales

PRIVACY POLICY

Last updated March 22, 2024

Privacy Notice for Olasales (‘we’, ‘us’, or ‘our’)

This privacy notice describes how and why we may collect, store, use, and share (‘process’) your information when you use our services (‘Services’), such as when you:

■ Visit our website at https://olasales.com or any website of ours that links to this privacy notice.

■ Engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at sales@olasales.com.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process?

When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about the personal information you disclose to us.

Do we process any sensitive personal information?

We do not process sensitive personal information.

Do we receive information from third parties?

We do not receive any information from third parties.

How do we process your information?

We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information?

We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe?

We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights?

Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights?

The easiest way to exercise your rights is by submitting a data subject access request or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the privacy notice in full.

  1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short, we collect personal information that you provide to us. We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

■ names

■ phone numbers

■ email addresses

■ usernames

■ passwords

■ contact preferences

■ billing addresses

■ debit/credit card numbers

■ contact or authentication data

Sensitive Information

We do not process sensitive information.

Payment Data

We may collect data necessary to process your payment if you make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/gb/privacy.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short, some information such as your Internet Protocol (IP) address and/or browser and device characteristics, is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

Log and Usage Data: Our servers automatically collect service-related, diagnostic, usage, and performance information when you access or use our Services, which we record in log files. Depending on your interaction with us, this data may include your IP address, device information, browser type and settings, and activity within the Services (such as date/time stamps associated with your usage, viewed pages and files, searches, and other actions). Device event information, including system activity, error reports (sometimes called ‘crash dumps’), and hardware settings, may also be included.

Device Data: We gather device data, such as information about the computer, phone, tablet, or other device you use to access our Services. This data may encompass your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration.

Location Data: Information about your device’s location, which can be precise or imprecise, is also collected. The extent of data collected depends on your device type and settings. For example, geolocation data based on your IP address may be collected using GPS and other technologies. You can opt out of providing this information by either refusing access or disabling the Location setting on your device. However, opting out may restrict access to certain Services features.

HOW DO WE PROCESS YOUR INFORMATION?

Account Management: We process your personal information to facilitate account creation, authentication, and overall account management, ensuring the smooth functioning of your account.

Service Delivery: Your information is processed to deliver and facilitate the delivery of services you request.

User Support: Inquiries and support requests are addressed by processing your information to provide assistance and resolve issues.

Administrative Communication: Information processing facilitates the sending of administrative details regarding our products, services, policy changes, and similar updates.

Order Fulfilment: Processing your information ensures the fulfilment and management of orders, payments, returns, and exchanges made through our Services.

User Interaction: Information may be processed to enable user-to-user communications through our platforms.

Feedback Collection: Your information may be processed to solicit feedback and engage with you regarding your experience with our Services.

Marketing and Advertising: Processing personal information enables us to send marketing and promotional communications, deliver targeted advertising, and assess the effectiveness of marketing campaigns.

Security and Protection: Information processing supports efforts to maintain the safety and security of our Services, including fraud monitoring and prevention.

Usage Analysis: Processing information about how our Services are used aids in understanding usage trends and improving user experience.

Legal Basis for Processing:

Consent: Processing occurs based on your consent for specific purposes, which can be withdrawn at any time.

 

Contractual Obligations: Personal information is processed to fulfil contractual obligations, including providing Services or responding to pre-contractual inquiries.

Legitimate Interests: Processing occurs based on legitimate business interests, provided they do not override your interests and fundamental rights.

Legal Obligations: Processing may be necessary for compliance with legal obligations, such as cooperation with law enforcement or disclosure in legal proceedings.

Vital Interests: Information may be processed to protect vital interests, including situations involving potential threats to safety.

Data Controller: We generally act as the data controller for personal information processed under European data protection laws, determining the means and purposes of processing. This notice does not apply to personal information processed on behalf of our customers, where they act as data controllers.

Legal Bases in Canada: In Canada, processing may occur with express or implied consent, or under exceptional circumstances permitted by law, including for investigations, compliance, or protection of individuals’ interests.

  1. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

 

In specific situations, we may need to share your personal information, including:

Business Transfers: Your information may be shared or transferred in connection with mergers, sales of company assets, financing, or acquisitions.

Use of Google Analytics: We may share your information with Google Analytics for tracking and analyzing the use of our Services. Opt-out options are available through various means.

  1. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

 

We may employ cookies and similar tracking technologies to collect and store your information. Details regarding usage and how to refuse certain cookies are provided in our Cookie Notice.

  1. HOW LONG DO WE KEEP YOUR INFORMATION?

We retain your information for as long as necessary to fulfil the purposes outlined in this privacy notice, unless otherwise mandated by law. We strive to delete or anonymize personal data when no longer needed.

  1. HOW DO WE KEEP YOUR INFORMATION SAFE?

We implement organizational and technical security measures to protect your personal information. While we strive to safeguard your data, no system can be guaranteed 100% secure.

  1. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly collect data from or market to individuals under 18 years of age. If such data is inadvertently collected, we take prompt action to delete it upon discovery.

  1. WHAT ARE YOUR PRIVACY RIGHTS?

In regions such as the EEA, UK, Switzerland, and Canada, you have rights allowing greater access to and control over your personal information. You may exercise these rights by contacting us.

  1. CONTROLS FOR DO-NOT-TRACK FEATURES

We do not currently respond to Do-Not-Track browser signals. If standards for online tracking change in the future, we will update our practices accordingly.

  1. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

Residents of California, Colorado, Connecticut, Utah, and Virginia are granted specific rights regarding access to their personal information. Details regarding the categories of personal information collected are provided.

We will utilize and retain the collected personal information as necessary to provide the Services or for the following purposes:

  • Category A: As long as the user maintains an account with us.
  • Category B: As long as the user maintains an account with us.
  • Category C: As long as the user maintains an account with us.
  • Category D: As long as the user maintains an account with us.
  • Category E: As long as the user maintains an account with us.

Additionally, we may gather other personal information outside of these categories through various interactions, including:

Receiving assistance through our customer support channels.

Participating in customer surveys or contests.

Facilitating the delivery of our Services and responding to inquiries.

How do we use and share your personal information?

Refer to the “HOW DO WE PROCESS YOUR INFORMATION?” section to understand how we utilize your personal information.

Will your information be shared with anyone else?

We may disclose your personal information to our service providers under written contracts between us and each service provider. Further details on how we disclose personal information are provided in the “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” section.

We may also use your personal information for internal business purposes, such as conducting internal research for technological development and demonstration. This does not constitute ‘selling’ your personal information.

We have not disclosed, sold, or shared any personal information with third parties for business or commercial purposes in the past twelve (12) months. We do not intend to sell or share personal information belonging to website visitors, users, and other consumers in the future.

California Residents.

Under the California Civil Code Section 1798.83, also known as the ‘Shine The Light law, California residents have the right to request and obtain, once a year and free of charge, information about categories of personal information (if any) disclosed to third parties for direct marketing purposes, and the names and addresses of all third parties with which personal information was shared in the immediately preceding calendar year.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. Contact us to request removal, ensuring to include the email address associated with your account and a statement confirming California residency.

CCPA Privacy Notice.

This section applies solely to California residents under the California Consumer Privacy Act (CCPA). Under the CCPA, you have the following rights:

Right to request deletion of data

Right to be informed

Right to non-discrimination

Right to limit use and disclosure of sensitive personal information

For further details on how to exercise these rights and our verification process, please refer to the relevant section in our privacy notice.

Colorado Residents

This section pertains to Colorado residents under the Colorado Privacy Act (CPA). Under CPA, you have specific rights, including:

  • Right to be informed whether or not we are processing your personal data
  • Right to access, correct inaccuracies, and request deletion of your personal data
  • Right to obtain a copy of the personal data previously shared with us
  • Right to opt out of processing personal data for targeted advertising, sale of personal data, or profiling in decisions producing legal or similarly significant effects (“profiling”)

Please note that these rights are not absolute, and we may decline requests as permitted by law. For further details, refer to the CPA section of our privacy notice. To submit a request to exercise these rights described above, please email sales@olasales.com or submit a data subject access request.

If we decline to take action regarding your request and you wish to appeal our decision, please email us at sales@olasales.com. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. Connecticut Residents

This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act (CTDPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

  • Right to be informed whether or not we are processing your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your personal data

Right to request deletion of your personal data

  • Right to obtain a copy of the personal data you previously shared with us
  • Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (profiling’)

To submit a request to exercise these rights described above, please email sales@olasales.com or submit a data subject access request.

If we decline to take action regarding your request and you wish to appeal our decision, please email us at sales@olasales.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Utah Residents

This section applies only to Utah residents. Under the Utah Consumer Privacy Act (UCPA), you have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

  • Right to be informed whether or not we are processing your personal data
  • Right to access your personal data
  • Right to request deletion of your personal data
  • Right to obtain a copy of the personal data you previously shared with us
  • Right to opt out of the processing of your personal data if it is used for targeted advertising or the sale of personal data

To submit a request to exercise these rights described above, please email sales@olasales.com or submit a data subject access request.

Virginia Residents

Under the Virginia Consumer Data Protection Act (VCDPA):

‘Consumer’ means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

‘Personal data’ means any information that is linked or reasonably linkable to an identified or identifiable natural person. ‘Personal data’ does not include de-identified data or publicly available information.

‘Sale of personal data’ means the exchange of personal data for monetary consideration.

If this definition of ‘consumer’ applies to you, we must adhere to certain rights and obligations regarding your personal data.

Your rights with respect to your personal data

  • Right to be informed whether or not we are processing your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your personal data
  • Right to request deletion of your personal data
  • Right to obtain a copy of the personal data you previously shared with us
  • Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (profiling)

Exercise your rights provided under the Virginia VCDPA

You may contact us by email at sales@olasales.com or submit a data subject access request.

If you are using an authorised agent to exercise your rights, we may deny a request if the authorised agent does not submit proof that they have been validly authorised to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you and your consumer’s request. If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at sales@olasales.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

  1. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020 (Privacy Act).

This privacy notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:

■ offer you the products or services that you want

■ respond to or help with your requests

■ manage your account with us

■ confirm your identity and protect your account

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section ‘HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?’

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand’s Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section ‘HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand’s Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section ‘HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:

The Information Regulator (South Africa)

General enquiries: enquiries@inforegulator.org.za

Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

  1. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated ‘Revised’ date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

  1. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Luke Thompson, by email at sales@olasales.com, by phone at +1 888-994-8993, or contact us by post at:

Olasales

103 King Street West,

Suite 1900 Toronto,

M5X 1E3

Canada

If you are a resident in the United Kingdom, we are the ‘data controller of your personal information. We have appointed Luke Thompson to be our representative in the UK. You can contact them directly regarding our processing of your information, by email at sales@olasales.com. by visiting https://olasales.app, by phone at +1 888-994-8993, or by post to:

103 King Street West,

Suite 1900 Toronto,

M5X 1E3

Canada

  1. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.