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Global Privacy Policy​

Onsa LLC, and its parent entity, Onsa Inc “Onsa” or “we,” “us,” “our”) respects your concerns about privacy and values our relationship with you. This Privacy Policy (“Policy”) applies to the data collected on any mobile app or website where this policy is linked, as well as any features, or content we own or operate (collectively, the “Services”). Please read this Policy carefully, because by using the Services you are acknowledging that you understand and agree to the terms of this Policy. In addition, please review our Terms of Service, which governs your use of the Services and any content you submit to the Services.

In this Privacy Policy, we cover:
  • Information We Collect
  • How We Collect Information
  • How We Use Your Information
  • Who We Share Information With
  • Do Not Track
  • Our Site is Not Intended for Children
  • Legal Bases for Processing
  • Your Rights
  • Information We Collect
  • How We Collect Information
  • How We Use Your Information
  • Who We Share Information With
  • Do Not Track
  • Our Site is Not Intended for Children
  • Legal Bases for Processing

Information We Collect 

Onsa (and the vendors we hire to perform business functions on our behalf) may collect, receive, and develop several categories of personal information:
  • account registration information, such as your name, email, user name and password, telephone number and preferences when using our Services.
  • identification information, such as your full name, date of birth, nationality, gender, signature, utility bills, photographs, and/or government identification numbers (which may include your social security number or equivalent, driver’s license number, and passport number).
  • transaction information, such as trading activity, order activity, withdrawals and account balances.
  • institutional information, such as an institution’s legal name, employer identification number (or comparable number issued by a government), and proof of legal formation (e.g., articles of incorporation).
  • financial information, such as your bank account information; tax identification information; credit history, and credit scores.
  • employment-related information, such as your job title and salary information.
  • correspondence, such as information you provide when you contact us with questions, feedback, survey responses, or otherwise communicate with us.
  • internet activity information, such as your IP address, unique device ID, browser type and language, operating system, and information collected via cookies and similar technologies (described below), including pages visited on our site, referring and exit pages, and the dates and times of the visits.

How We Collect Information

We collect and obtain personal information from the following categories of sources:
    • from you. We collect information that you provide to us when you open an account or provide account information, contact us, or make a purchase.
    • from your device, including through:
      • cookie & similar technologies. We, along with our advertising/analytics partners and service providers (who deliver services on our behalf), may set cookies, web beacons, pixels, tags, scripts, and software development kits (SDKs) on your browser or device when you visit our website in order to remember user preferences, analyze trends and site performance, administer the site, track users’ movements and behavior around the site, target users with advertisements, measure advertising effectiveness, and prevent fraud.
    • from other sources, including the following:
      • public databases and ID verification partners. We obtain information about you from public databases and ID verification partners to verify your identity in accordance with applicable law (e.g., anti-money laundering laws).
      • blockchain data. We may analyze public blockchain data and obtain information about your transactions from blockchain analysis providers to ensure parties utilizing our Services are not engaged in illegal or prohibited activity under our Terms of Use, and to analyze transaction trends for research and development purposes.
      • data append services, data brokers, and joint marketing partners. We receive personal information from these sources so that we can better understand which of our Services may be of interest to you.

How We Use Your Information

We may use your personal information:
  • to provide you with our Services. We use your personal information to provide you with our Services. For example, in order to facilitate account creation/maintenance, money/peer-to-peer transmissions, and buying and selling cryptocurrencies and securities.
  • to improve our Services. We may use personal information to research, analyze, and understand how users access and use our Services, both on an aggregated and individualized basis, in order to help us improve our Services and develop new products.
  • to correspond with you. We use personal information to provide you with customer support anytime you reach out to us with questions about our Policy or Terms of Use, or issues arising from your account. We also use personal information to send customers technical alerts, updates, security notifications, and administrative communications.
  • for marketing purposes. We may use your personal information to communicate with you regarding certain products, services or promotions offered by Onsa or certain third products or services we believe you may be interested in, provided that you have not already opted out of receiving such communications.
  • to detect, investigate, and prevent fraud and security issues. We use your personal information as necessary to protect our company, our customers, and our business partners, including by investigating and preventing fraudulent activities, unauthorized access to the Services, and other illegal activities.
  • comply with laws and regulations. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal processes, such as to comply with anti-money laundering laws, to report to credit bureaus, and to respond to subpoenas or requests from government authorities.
We may also use personal information for any other purposes disclosed to you at the time your information is collected or pursuant to your consent.

Who We Share Information With

We share your personal information with:
  • service providers. We share your personal information with service providers that we have engaged to perform services on our behalf. This includes service providers that: conduct research and analytics; create content; provide customer, technical or operational support; conduct or support marketing (such as email or advertising platforms); host the Services; maintain databases; send or support online or mobile advertising; and otherwise support or help us provide the Services.
  • advertising and marketing partners. We share your personal information with other third parties, including advertising/analytics partners who enable the delivery of interest-based advertising to users.
  • affiliates, investors and business partners. We share your personal information with our affiliates, investors and business partners, subject to the terms of this Policy or otherwise as we disclose to you at the time the data is collected.
  • law enforcement agencies, governmental authorities or regulators. We will share your personal information when we believe it is appropriate to comply with the law, enforce or apply our conditions of use and other agreements, or protect the rights, property, or safety of the Services, our users, or others.
  • mergers, acquisitions, and business transfers. We will share your personal information if we are acquired by or enter into a merger with another company, or otherwise reorganize our business.
We may also share personal information for other reasons we may describe to you from time to time as permitted by law.

Our Site is Not Intended for Children

We do not knowingly collect personal information from children under 18. If you are a parent or legal guardian and you think your child under 18 has given us information, you can contact us at privacy@onsa.com.

Legal Bases for Processing

The personal information we process may qualify for multiple legal bases for processing under Article 6 of the General Data Protection Regulation (and similar laws that specify legal bases for processing). Below are our primary legal bases for processing personal information covered under such laws:
  • legal obligation. We process personal information to conduct anti-fraud and identity verification and authentication checks and to fulfill our retention obligations.
  • contractual obligation. We process personal information to satisfy our obligations to you under our Terms of Use, including to provide you with our Services and customer support, and to optimize and enhance Onsa.
  • legitimate interest. We process personal information to monitor the usage of Onsa, conduct automated and manual security checks of our service, and to protect our rights.
  • consent. We process personal information to market Onsa and our Services to you. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before consent is withdrawn.

Your Rights

You have the following rights, where provided under applicable law, regarding your personal information (each of which are subject to various exceptions and limitations):
  • the right to be informed. You have the right to receive confirmation as to whether or not we are processing your personal information, to have access to your personal information, and to be provided with clear and easily understandable information about how we use your information and your rights.
  • the right to rectification. You are entitled to have your personal information corrected if it is inaccurate or incomplete. We encourage you to promptly update your personal information if it changes.
  • the right to erasure/deletion. You have the right to request that we delete your personal information. We may have the right to retain certain information. It may be impossible to completely delete your information without some residual information because of backups.
  • the right to restrict processing. You have the right to request that we limit our use of your personal information in some cases. For example, if the information we have is inaccurate or you object to our legitimate interest for processing your information, you may restrict our use of that information.
  • the right to object. You have the right to object to certain types of processing, in particular processing based on our legitimate interests. You also can object at any time to your information being used for direct marketing purposes. Where you object to processing for direct marketing purposes, the personal information shall no longer be processed for such purposes.
You may correct your personal information and exercise your privacy preferences by writing us at privacy@onsa.com. Please include your name, address, and/or email address when you contact us. We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us. You may designate an authorized agent to make a request on your behalf. When submitting the request, please ensure the authorized agent identifies himself/herself/itself as an authorized agent. If you have any concerns about our practices, you have the right to lodge complaints with the appropriate authorities

Your California Rights

If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email, or write to us at privacy@onsa.com. Indicate in your email that you are a California resident making a “Shine the Light” inquiry.

Additional Choices

You have certain choices about how we use your personal information, including with respect to.

    • marketing communications. We may send you emails regarding the Services. If you do not want to receive promotional emails, you can click the unsubscribe link in any marketing email from us or contact us at privacy@onsa.com and let us know. However, there may be certain administrative emails that you will have to continue to receive in order to use the Services.
    • cookies. You also have choices with respect to the following types of cookies that we use on our website:
      • from your device, including through:
      • cookie & similar technologies. We, along with our advertising/analytics partners and service providers (who deliver services on our behalf), may set cookies, web beacons, pixels, tags, scripts, and software development kits (SDKs) on your browser or device when you visit our website in order to remember user preferences, analyze trends and site performance, administer the site, track users’ movements and behavior around the site, target users with advertisements, measure advertising effectiveness, and prevent fraud.

In the U.S., you can opt out of tracking on our website or others for online behavioral advertising by visiting the Digital Advertising Alliance’s Consumer Choice page at http://www.aboutads.info/choices/ or the Network Advertising Initiative’s page at http://www.networkadvertising.org/choices/. In Europe, you can make choices about whether to allow tracking when you first visit our website and are asked to accept trackers. You may opt out of receiving targeted advertising in mobile apps through participating members of the DAA by installing the AppChoices mobile app, available at https://youradchoices.com/appchoices.

You may also disable cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to disable all cookies (including strictly necessary cookies) you may not be able to access all or parts of our website.

Disabling a cookie or category of cookie does not delete the cookie from your browser. You will need to do this separately within your browser. If you have disabled one or more analytical cookies, we may still use information collected from cookies prior to your disabled preference being set.

Do Not Track

When we collect tracking information on our website, we do not respond to users’ Do Not Track settings in browsers. However, you may choose to decline cookies in your browser settings on a desktop computer, or by declining tracking in your settings on a mobile device.

International Data Transfers

Onsa is headquartered in the United States and may have service providers in other countries. Your personal information may be transferred to the United States or other locations outside of your state, province, country, or other governmental jurisdiction where privacy laws may not be as comprehensive as those in your jurisdiction.

Third Party Links and Websites

If you click on a link to a third party website, you will be taken to a website we do not control. This Policy does not apply to the privacy practices of that website, which may collect information from you. Read the privacy policy of other websites carefully. We are not responsible for these third party websites or their policies.

Security

While we take reasonable steps to protect your personal information, nothing on the internet is 100% secure. For these reasons, we cannot guarantee that all of your personal information will never be disclosed in ways you do not expect or which are not described in this Policy.

Changes to this Policy

From time to time we may change our privacy policies. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy on our website. Please check our website periodically for updates. Your continued use of our website means that you consent to the collection, use and disclosure of your personal information as set out in the updated Policy.

Questions/Contact Us

If you have questions about the guidelines described in this Policy, please email us directly at privacy@onsa.com.

contact@onsa.com

Launching fall 2020