Ogee Privacy Policy
Last Updated: February 5, 2025
Your privacy is very important to Ogee, Inc. (“we”, “us” or “our”). This Privacy Policy spells out Ogee’s commitment to respecting the privacy of the members and visitors of our website located at https://ogee.com/ (the “Site”).
This Privacy Policy describes how Ogee collects, uses, discloses, retains and otherwise manages your personal information. It also describes the choices available to you regarding our use of your personal information. PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY. By using this Site, you accept the terms of this Privacy Policy and our Terms of Service and consent to our collection, use, disclosure and retention of your information as described in this Privacy Policy.
We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of a notice on this Site prior to the change becoming effective.
1. Collection of Personal Information
a. Information You Provide
We collect the following personal information from you:
- Contact information, such as name, email address, mailing address, and phone number
- Billing information, such as bank or credit card number and billing address
- Login information, such as username and password
- Information for rewards, such as birthday, which relatedly reveals your age
- Preferences information such as product wish lists, order history and marketing preferences
- Personal information that you provide to us in response to questionnaires we may offer to personalize our product offering for you, such as to find your shade or contour
- Photographic images that you provide to us or that you use in connection with your use of the Site, including your likeness, which may also reveal your gender
o If you post a photograph on social media and tag us or if you post a comment on our social media pages, we will collect the photograph or content of that message. Please note that if you choose to post photograph on social media and tag us or post a comment on any of our social media pages, any information you post will be visible to any other visitors to that social media page. We are not responsible for any personal information you include in such posts or for any use of such information by any other visitor to the social media page.
b. Information Collected Automatically
In addition, information about your computer hardware and software is automatically collected by Ogee when you use the Site. This information may include:
· Type of operating system
· Type of browser
· Language preference
· Access times and dates
· Type of device
· Internet service provider
· Wi-Fi usage
· Default search preference
· Referring website addresses
· Search queries
· Device ID
· IP address
· Geographic location based upon your IP address
· Browsing history
· MAC address
· Technical unique identifier, such as UDID
· Other technical information such as protocol status and substatus, bytes sent and received, and server information.
We may also collect information regarding traffic patterns, the actions taken on our Site, including the user’s click-stream, and your interaction with our Site and advertisements. This information is used by us for our business purposes, including for the operation and improvement of the Site, for technical troubleshooting, to maintain quality of the Site and to provide general statistics regarding use of the Site. We may also receive similar data from our business partners, including online advertising networks, and from social media platforms, such as Facebook, Instagram and TikTok, subject to your registration and privacy settings with such third-party social media platforms.
c. Cookies and Other Tracking Technologies
Cookies
A cookie is a small file containing a string of characters that is sent to your computer when you visit a website or use an online service. When you visit the website or use the service again, the cookie allows that website or online service to recognize your browser or device. Cookies may store unique identifiers, user preferences and other information.
We may use “session cookies” or “persistent cookies.” Session cookies are temporary and expire once you close your browser or once your session ends. Persistent cookies remain on your device for much longer or until you or your browser erase them. Persistent cookies have varying durations that are dependent on their expiration date.
The types of cookies we may use on the Site include:
· Strictly necessary cookies – these cookies are necessary for the Site to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Site will then not work.
· Performance cookies – these cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Site. They help us to know which pages are the most and least popular and see how visitors move around the Site. If you do not allow these cookies we will not know when you have visited our Site, and will not be able to monitor the Site’s performance.
· Targeting cookies – these cookies may be set through our Site by our advertising partners. Such advertising partners may use them to build a profile of your interests and show you relevant advertisements on other websites. If you do not allow these cookies, you will experience less targeted advertising. See Section 3 (Interest-Based Advertising) for more information.
We may use Google Analytics, for example, which sets cookies on the Site to help analyze how visitors use the Site. If you would like to opt-out from the use of your information by Google Analytics, you may use Google Analytics’ opt-out browser add-on designed for this purpose.
Web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org. Some web browsers provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet or mobile device. Although users are not required to accept cookies, as noted above, blocking or rejecting them may prevent access to some features available through the Site. You may manage your cookie preferences on the Site by clicking here.
Web Beacons and Pixels
A pixel is an HTML code snippet embedded in a website or email that collects information about user behaviors and interactions with the website or email.
We may utilize pixels both on certain aspects of the Site and in HTML-formatted email messages to you. Pixels may be used for the purpose of, among other things, measuring the success of our marketing campaigns, compiling statistics about Site usage and tracking the activities of users of the Site and email recipients. For instance, we may use pixels from Meta, TikTok, Google, Pinterest and Snapchat on the Site to enable us to create targeted advertisements and measure the effectiveness of our advertisements. For additional information on interest-based advertising, please see Section 2 (Interest-Based Advertising).
2. Interest-Based Advertising
We may collect information about your online activities on our Site to provide you with advertising about products tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our advertisements are served.
You may see certain advertisements on other websites because we work with advertising partners (including advertising networks) to engage in remarketing and retargeting activities. Our advertising partners allow us to target our messaging to users through demographic, interest-based and contextual means. These partners track your online activities over time and across websites, including our Site, by collecting information through automated means, including through the use of third-party cookies, web beacons and pixels. They use this information to show you advertisements that may be tailored to your individual interests. The information our advertising partners may collect includes data about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Site and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts. For example, we utilize certain of our advertising partners’ targeted advertising services to show you our advertisements on other websites based on your prior visits to our Site and other online activity.
Provided that a company participates in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising, you may opt out of interest-based advertising generally through the Network Advertising Initiative website or by visiting http://www.aboutads.info/choices/ (web-based advertising) or http://www.aboutads.info/appchoices (for mobile advertising). To learn more, please visit the websites operated by the Network Advertising Initiative and Digital Advertising Alliance at www.networkadvertising.org/choices. Opting-out does not mean that you will stop receiving advertisements from us. It means that you still stop receiving advertisements from us that have been targeted to you based on your visits and browsing activity across websites over time.
3. Use of Personal Information
We use this information to:
- Provide the Site to you
- Fulfill your order
- Send you an order confirmation
- Operate, improve and personalize the products we offer, and to give you a more consistent and personalized experience when interacting with us
- Send you requested product information
- Respond to customer service requests
- Send you surveys regarding your satisfaction with our products and overall experience with us
- Create and manage your account
- Administer our rewards programs
- Administer giveaways
- Personalize our advertising, marketing communications, shopping experiences and promotional offers and to deliver promotions and offers to you that we think may interest you
- If you sign up for our email list or to receive promotional text messages, to send you emails or text messages about products or offers that we think might be of interest to you
- Respond to your questions and concerns
- Improve our Site user experience and marketing efforts
- Conduct research and analysis
- For security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Site
- For our business purposes, such as data analysis, audits, developing new products, enhancing our Site, improving our products and services, identifying Site usage trends, and determining the effectiveness of our promotional campaigns;
- As we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce this Privacy Policy and our Terms of Service; (v) to protect our operations; (vi) to protect our rights, privacy, safety or property, and/or that of you, or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.
4. Information Sharing
We may also disclose your information:
- With Third Party Service Providers Performing Services on Our Behalf. We share your personal information with our service providers to perform the functions for which we engage them. For example, we may use third parties to host the Site or assist us in providing functionality on the Site, provide data analytics on the Site, send out emails and text messages about the Site and our products and to process payments.
- For Legal Purposes. We also may share information that we collect from users as needed to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose information as we deem necessary to respond to subpoenas, regulation, binding order of a data protection agency, legal process, governmental request or similar legal or regulatory process
- With Your Consent. We may share your personal information io any other third party with your prior consent to do so.
- With Business Partners. If Ogee engages in a joint promotion with an affiliate and/or partner, we may share your contact information with our affiliate and/or partner to be used in relation to the promotion.
- Changes of Control. If Ogee is involved in a corporate transaction, such as a merger, acquisition, sale of all or substantially all of our assets, divestiture, consolidation or even in the unlikely event of bankruptcy, your personal information may be one of the assets that is transferred.
5. Third-Party Websites and Online Services
Our Site may contain links to third-party websites and online services. When you click on a link to any other website or online service, you will leave our Site and go to another site, and another entity may collect information from you. We have no control over, do not review, and cannot be responsible for, these external websites and online services or their content. Please be aware that the terms of this Privacy Policy do not apply to these external websites and online services or content, or to any collection of your personal information after you click on links to such external websites and online services. We encourage you to read the privacy policies of every website and online service you visit. The links to third-party websites or online services are for your convenience and do not signify our endorsement of such third parties or their products, content or websites or online services.
6. Social Media
Some aspects of the Site may allow you to interface with social media, such as Facebook, Instagram, TikTok, Pinterest and Snapchat. We will attempt to identify these aspects of the Site to you, for example, by identifying them with the applicable third-party logos or trade names. By using these interfaces, you will allow us to access information about you from those other online services, including information and other content that you submit to those online services. If you interface with the Site through your social media account, we may contact you or enable you to share your experience and content via your social media account, which information may be publicly viewed by other users of those services. For a description on how such social media services and other third-party platforms, plug-ins, integrations, and applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings with that service or platform.
7. Consent to Receive Communications
By providing your phone number and clicking submit on the Site, you agree to our Terms of Service and this Privacy Policy, and authorize us to make or initiate sales calls, text messages and prerecorded voicemails to that phone number using an automated system. Your agreement is not a condition of purchasing any products, goods or services. Message & data rates may apply and message frequency may vary. Reply STOP to unsubscribe. HELP for help.
8. Your Rights and Choices
You may choose to stop receiving our marketing emails and text messages by following the unsubscribe instructions included in such emails and text messages, updating your communications preferences in your membership account on the Site or contacting us at:
Ogee
One Lawson Lane, Suite 130
Burlington, VT 05401
Email: support@ogee.com
Phone: 1.888.376.8037
If you have linked to your social media account and decide at any time that you no longer wish to have your social media account (e.g., Facebook) linked to your account, then you may de-link the social media account in the “preferences” section in your account settings. You may also manage the sharing of certain personal information with us when you connect with us through your social media account, such as through Facebook. Please refer to the privacy settings of your social media account to determine how you may adjust our permissions and manage the interactivity between the Site and your social media account.
You may change any of your personal information in your account by editing your profile within your account or by sending an email to us at the email address set forth below. You may request deletion of your personal information by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud or similar purposes.
9. Do Not Track
Our Site does not currently take any action when it receives a Do Not Track request. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, visit www.donottrack.us.
10. Security
The security of your personal information is important to us. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (“SSL”).
We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.
If you have any questions about security on our Site, you can contact us at:
Ogee
1 Lawson Lane, Suite 130
Burlington, VT 05401
Email: support@ogee.com
Phone: 1.888.376.8037
11. A Note About Children
No parts of our Site are directed to or designed to attract anyone under the age of 16. We do not intentionally gather personal information from visitors who are under the age of 16. If a child under 16 submits personal information to us and we learn that the personal information is the information of a child under 16, we will attempt to delete the information as soon as possible. If you believe that we might have any personal information from a child under 16, please contact us at support@ogee.com.
12. Nevada Residents
Under Nevada law, Ogee does not sell your personal information. However, if you are a Nevada resident, you may submit a request that we not sell any personal information we have collected about you by contacting us as at:
Ogee
1 Lawson Lane, Suite 130
Burlington, VT 05401
Email: support@ogee.com
Phone: 1.888.376.8037
13. California Residents
The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CPRA”) provides California residents with specific rights regarding their personal information. The below describes such rights and how you may exercise such rights, and our information practices, including the categories of personal information we collect, use, retain, disclose, sell or share, and how and why we collect, disclose, sell or share such information.
Consumer Rights
Right to Know
You have the right to request that we disclose what personal information we collect, use, disclose, sell or share. Specifically, you may request that we disclose to you the following:
1. The categories of personal information we have collected about you.
2. The categories of sources from which the personal information is collected.
3. The business or commercial purpose for collecting, selling or sharing personal information.
4. The categories of third parties with whom we disclose personal information.
5. The specific pieces of personal information we have collected about you.
You may also request that we disclose to you:
1. The categories of personal information that we have sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each third party to whom the personal information was sold or shared.
2. The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
Right to Request Deletion
You have the right to request that we delete any personal information about you which we have collected from you. If it is necessary for us to maintain your personal information for certain purposes, we are not required to comply with your deletion request. If we determine that we will not delete your personal information when you request us to do so, we will inform you and tell you why we are not deleting it.
Right to Opt-Out of Sale or Sharing of Personal Information
You have the right to direct a business that sells or shares personal information about you to third parties not to sell or share your personal information. We do not sell your personal information for monetary consideration. However, we do use cookies and other tracking technologies as stated above in Section 1.c. (Cookies and Other Tracking Technologies) for targeted advertising purposes. The collection of data through certain cookies and other tracking technologies for our targeting advertising purposes may be considered a “sale” and is considered “sharing” under the CPRA. To opt-out of having your information sold and shared with third-party website analytics and digital advertising service providers for this purpose, visit our “Do Not Sell or Share My Personal Information ” web page.
Right to Correct Inaccurate Personal Information
You have the right to request a business that maintains inaccurate personal information about you to correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.
Right to Limit Use and Disclosure of Sensitive Personal Information
You have the right to direct a business that collects sensitive personal information about you to limit its use of your sensitive personal information (1) to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services; (2) for certain business purposes; and (3) as authorized by the implementing regulations of the CPRA. Ogee does not use or disclose the above sensitive personal information for any purpose other than those permitted under the CPRA.
No Discrimination
You have the right not to be discriminated against because you exercised any of your aforementioned rights.
How to Submit a Request
To exercise the rights described above, you must submit a verifiable request to us. You can do so by calling us at 1.888.376.8037 or by visiting https://ogee.com/pages/customer-data-requests.
If you maintain an online account with us, we may verify your identity for a request through the normal account authentication process, meaning you may need to sign on with your username and password.
To submit a verifiable request, you will be asked to provide certain information to help us verify your identity. The information we ask you to provide to initiate a request may differ depending upon the type of request, the type, sensitivity and value of the personal information that is the subject of the request, and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors.
You may designate an authorized agent to make a request on your behalf by providing the agent with signed written permission to do so.
If we cannot verify your identity or authority to make the request, we will not be able to comply with your request. We will inform you if we cannot verify your identity or authority. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.
How we collect, use, disclose, sell and share personal information of consumers
Ogee has collected the following categories of personal information and used, disclosed, sold or shared such information in the twelve (12) months prior to the effective date of this Privacy Policy:
· Identifiers, such as name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
· Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, physical characteristics or description, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.
· Commercial information, such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
· Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
· Geolocation data.
· Visual information (e.g., photographs).
Each of the above categories are disclosed for a business or commercial purpose as described above in Section 3 (Use of Personal Information) to the third parties listed in Section 4 (Information Sharing).
The following categories of personal information were sold or shared in the twelve (12) months prior to the effective date of this Privacy Policy:
· Identifiers, such as unique personal identifier, online identifier, Internet Protocol address, or other similar identifiers.
· Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement
· Geolocation data.
Such information is sold to or shared with our third-party website analytics and digital advertising service providers.
We share or sell such information to:
- Provide the Site to you
- Operate, improve and personalize the products we offer, and to give you a more consistent and personalized experience when interacting with us
- Personalize our advertising, marketing communications, shopping experiences and promotional offers and to deliver promotions and offers to you that we think may interest you
- Improve our Site user experience and marketing efforts
- Conduct research and analysis
- For security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Site
- For our business purposes, such as data analysis, audits, developing new products, enhancing our Site, improving our products and services, identifying Site usage trends, and determining the effectiveness of our promotional campaigns;
- As we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce this Privacy Policy and our Terms of Service; (v) to protect our operations; (vi) to protect our rights, privacy, safety or property, and/or that of you, or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.
Ogee does not collect sensitive personal information. However, if you provide us with photographs or respond to our quizzes to help find your shade, it may be possible to infer your racial or ethnic origin. Ogee will only use and disclose such information as necessary to fulfill the purposes of collection or as permitted under the CPRA and we will not sell or share such information.
Ogee collects the personal information described above from or through the following categories of sources:
- You, directly and indirectly, including when you access the Site or make any purchases through the Site;
- Service providers, including those that provide analytics services to help us understand the activity on the Site.
Ogee will retain the personal information described above for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulation.
Financial Incentive – Rewards Program
Ogee offers various financial incentives, such as discounts and other benefits for customers who sign up to receive our marketing emails or join our loyalty program (the “Program”). When you participate in a financial incentive, we collect personal information from you, such as identifiers (like your name and email address) and commercial information (like your purchase history). You may opt-in to the Program at any time at https://ogee.com/account/register. Our rewards page located at: https://ogee.com/pages/rewards, and our Terms of Service describe the material terms of the Program. you may revoke your decision to opt-in to the Program at any time by contacting us at support@ogee.com.
In some cases, we may provide additional terms and conditions for a financial incentive, which we will present to you when you sign up. We value your personal information as the value of the offer or discount provided to you, and the value of your personal information is reasonably related to the value of the offer or discount presented to you.
Personal Information of Minors
Ogee does not have actual knowledge that it sells or shares personal information about minors under the age of 16.
California “Shine the Light” Law
Under California Civil Code Section 1798.83, also known as California’s “Shine the Light” law, California residents with whom we have an established business relationship are entitled to request and receive, free of charge, once per calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses in the previous calendar year. To request a copy, please contact us at support@ogee.com. Please be aware that not all information sharing is covered by the “Shine the Light” law requirements and only information on covered sharing will be included in our response.
14. Colorado, Texas, Utah, Virginia Residents
The categories of personal information we process about you is set forth in Section 1 (Collection of Personal Information) above. The purposes for processing such personal information are set forth in Section 3 (Use of Personal Information) above. We disclose the personal information we process about you with the third parties set forth in Section 4 (Information Sharing) above.
If you are a resident of Colorado, Texas, Utah, or Virginia you have the rights to:
- Confirm whether or not we are processing your personal information and access such personal information;
- For Colorado, Texas and Virginia residents, correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information;
- Delete personal information provided by, or, for Colorado, Texas and Virginia residents obtained about, you;
- Obtain a copy of your personal information we process, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance, where the processing is carried out by automated means; and
- Opt out of the processing of personal information for purposes of:
- Targeted advertising;
- The sale of personal information; or
- For Colorado, Texas and Virginia residents, profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. We do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
You may exercise these rights by:
· By Phone: 1.888.376.8037
· By Website: https://ogee.com/pages/customer-data-requests
Only you may make a verifiable request related to your personal information. The verifiable consumer request must:
· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information; and
· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We reserve the right to verify your identity in connection with any requests regarding personal information to help ensure that we provide the information we maintain to the individuals to whom it pertains and allow only those individuals to exercise rights with respect to that information. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
In the event we deny your request, you may appeal our denial by contacting us in the same manner by which you submitted your request.
We process your personal information for the purposes of targeted advertising, and under Colorado and Texas laws, our processing may qualify as a “sale”. We share your Internet activity, as described in Sections 1.c. (Cookies and Other Tracking Technologies) and 2 (Interest-Based Advertising) with our third-party website analytics and digital advertising service providers. To opt-out of such sharing of information with our third-party website analytics and digital advertising service providers, please visit our “Personal Data Use Opt-Out” web page. If you are an authorized agent making a request to opt-out on behalf of a consumer, we may require and request that you provide us with written permission signed by the consumer to verify that you are authorized to make such request.
Financial Incentive – Rewards Program
As mentioned in Section 13 (California Residents), Ogee offers various financial incentives, such as discounts and other benefits for customers who sign up to receive our marketing emails or join our loyalty program (the “Program”). When you participate in a financial incentive, we collect personal information from you, such as identifiers (like your name and email address) and commercial information (like your purchase history). Such information may be shared with our service providers, including our third-party website analytics and digital advertising service providers.
You may opt-in to the Program at any time at https://ogee.com/account/register. Our rewards page located at: https://ogee.com/pages/rewards, and our Terms of Service describe the material terms of the Program. you may revoke your decision to opt-in to the Program at any time by contacting us at support@ogee.com.
In some cases, we may provide additional terms and conditions for a financial incentive, which we will present to you when you sign up.
If you request to delete your personal information and such deletion makes it impossible to provide the Program to you, then we will provide an explanation of why the deletion of personal information makes it impossible to provide the Program to you.
15. A Note to Users Outside of the United States
If you are a non-U.S. user of the Site, by visiting the Site and providing us with data, you acknowledge and agree that your personal information may be processed for the purposes identified in the Privacy Policy. In addition, your personal information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of personal information may be less stringent than the laws in your country. By providing your data, you consent to such transfer.
16. EU/UK/Switzerland Residents
With respect to “personal data” as defined by Regulation (EU) 2016/679 (“GDPR”), any national law of an EU member state adopted pursuant to the GDPR, the United Kingdom Data Protection Act of 2018, and the Switzerland Federal Act on Data Protection (collectively, “European Data Protection Laws”), we serve as the “controller”.
We process the personal data set forth in Section 1 (Collection of Personal Information) above for the purposes set forth in Section 3 (Use of Personal Information) above. Our legitimate bases for processing such personal data include:
· Performance of Contract. We may use your information to perform our contractual services or prior to entering into an agreement with you. If you use the Site or if you contact us to request information about our products and services, we use your information to provide to you the features and functionality of the Site and our products and services.
· Legitimate Interest. We may use information for our legitimate interests, except where such interests are overridden by your interests or fundamental rights and freedoms. For instance, we may use your personal data to contact you and respond to your requests and inquiries, to administer our business including by creating statistical analyses, to identify prevent and detect fraud or to pursue or defend ourselves against legal claims.
· Consent. We may use your information with your consent. In these instances, we will ask you to grant us consent to use your information. You are free to grant or deny permission. If you deny permission, we will not be able to process your information to conduct the activity to which the consent relates. For example, we will not be able to send you marketing materials that you request. You are also free to withdraw your consent at any time. A withdrawal of consent will not affect processing that has been completed during the time in which the consent was valid. If you have granted us consent to use your information, we will use it only for the purposes specified when we request your consent.
· Fulfillment of Legal Obligations. We may use your information to comply with our legal obligations. To comply with regulations, laws or any authority requests, we may disclose your information to authorities or other officials or otherwise process your information pursuant to legal obligations we are subject to (e.g., respond to your requests to exercise your rights under European Data Protection Laws).
For information on whom we share your personal data with please refer to Section 4 (Information Sharing) above.
All personal data we collect is currently processed in the United States by us or by a party acting on our behalf. When you provide personal data to us, you consent to the transfer of your data to, and processing of your data in, the United States. The Site is currently hosted in the United States. We will transfer your personal data to the United States through the use of appropriate safeguards as required by European Data Protection Laws.
We will retain your information for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulation.
Under European Data Protection Laws, you have the following privacy rights, which you may exercise by contacting us at support@ogee.com with “GDPR Request” on the subject line and in the body of your message:
· Right of Access. You have the right to obtain confirmation as to whether your personal data is being processed, as well as access to the personal data along with certain information, including the purposes of the processing, the categories of personal data concerned and the recipients or categories of recipients to whom the personal data have been or will be disclosed.
· Right to Rectification. You have the right to rectify your inaccurate personal data and to complete any incomplete personal data, including by means of providing a supplementary statement.
· Right to Erasure or Right to be Forgotten. You have the right to erase your personal data under certain circumstances.
· Right to Restrict Processing. You have the right to restrict our processing of your personal data under certain circumstances.
· Right to Object. You have right to object, on grounds relating to your particular situation, at any time to our processing of your personal data, which is based on public interest or our legitimate interests, including the profiling of data. In this case, we will stop processing your data, except for where we have compelling legal grounds for the processing which override your interests, rights and freedoms, or for the exercise or defense of possible legal claims. You also have a right to object to the processing of your personal data for direct marketing purposes.
· Right to Data Portability. Under certain circumstances, you have the right to receive your personal data that you provided to us in a structured, commonly used and machine-readable format, and have the right to transmit such data to another controller without hindrance from us.
· Right to Withdraw Consent. If you have provided us with your consent for the processing of your personal data, you may withdraw your consent at any time to stop any further processing.
· Right to Lodge a Complaint. You have a right to lodge a complaint with a supervisory authority if you believe that our processing of your personal data violates the European Data Protection Laws.
17. Contact Information
You can contact us about this Privacy Policy by writing or emailing us at the address below:
Ogee
1 Lawson Lane, Suite 130
Burlington, VT 05401
Email: support@ogee.com
Phone: 1.888.376.8037