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Privacy Policy - Frequently Asked Questions (FAQ)

Last updated: December 7, 2023

🛣️ The protection of your personal data and information is something that we care a lot about here at Ontop. We are committed to making our data privacy practices as simple and transparent as possible. If you feel that anything in this Privacy FAQ is unclear or difficult to understand, please let us know by sending us an email to 📥legal@getontop.com. We are truly concerned in constantly improving your legal experience and welcome your feedback.

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Note: Any capitalized terms in these FAQ will follow the definitions of our Privacy Policy.

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To make a Personal Data Request, please visit our Ontop Privacy Center.

1. What is Personal Data?

At Ontop, we may process Personal Data, i.e. data that relates to an identified or identifiable individual or that is linked or linkable to that individual, no matter where the individual lives. 

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This means that data that directly identifies you — such as your name — is Personal Data, and data that does not directly identify you, but that can reasonably be used to identify you — such as your date of birth — is also Personal Data.

2. What are my Personal Data rights? ⚖️

At Ontop, we respect your ability to know, access, correct, transfer, restrict the processing of, and delete your Personal Data on our systems. We have provided these rights to our global customer base and if you choose to exercise these privacy rights, you have the right not to be treated in a discriminatory way nor to receive a lesser degree of service from Ontop. We do not sell your data. 

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To exercise your privacy rights and choices, please fill out the form at our Ontop Privacy Center. To help protect the security of your personal data, you may be required to confirm your identity.

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There may be situations where we cannot grant your request — for example, if you ask us to delete your data and we are legally obligated to keep a record of that data to comply with the law.

3. What Personal Data do you collect from me? 🧺

We collect and Process the following categories of Personal Data from you:

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● Contact and Account Data: The personal details provided when users sign up to our Service. This includes the user’s name, email address, telephone number, address, job title and password, organization (if a legal entity), and other ways for us to contact you.

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â—Ź Information about User Transactions: Details about the transactions you carry out and the payments to and from your accounts with us.

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● Payment Information: These can include credit card information or account details for other online payment methods (such as PayPal or Payoneer). If payments to us are made via third-party payment processing platforms, these third parties will collect your Personal Data related to such payments and we will not retain this information. In such cases, the third party’s privacy policy will apply.

â—Ź Data and Information Provided in IM Chats: To serve our users better, we make instant messaging (IM) tools available to our users. Any Personal Data or information provided via this medium will be collected and stored.

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â—Ź Biographical and Biometric Data: Details about you that are stored in documents in different formats, or copies of them. This could include things like (without limitation) data contained in your passport, national ID, social security or any other identification documents. For the purposes of background checks, third parties may collect selfie photos and/or videos that run facial recognition software for identity verification.

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â—Ź Personal Data Provided by Telephone: We have customer service agents available to speak with our Clients 24/7. Calls may be recorded and any Personal Data and/or information provided over the telephone, including payment information, will be collected and stored.

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‍● Non-Personal Information:  We may also collect information that is related to you but that does not personally identify you. Non-personal information also includes data that could personally identify you in its original form, but that we have modified (e.g. by aggregating, anonymizing, or de-identifying such information) in order to remove or hide any characteristics that may lead to your identification.

4. What Personal Data do you receive from other sources?  ⛲

We collect any other Personal Data and/or information you choose to provide to us through any and all available channels, participating in user/customer surveys or otherwise visiting and interacting with our Website and/or Platform.

5. How do you use my Personal Data? đź“Š

These are some of the ways we use your Personal Data, so we can provide the best experience for you:

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â—Ź To enable your contracts or financial transactions relating to our payroll services, as well as any requests you make or questions you ask us through our Platform or other communications channels.

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â—Ź So we can share marketing and promotional content with you, and get your meaningful feedback in our user or customer surveys.

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â—Ź For security purposes, included but not limited to our protection, as well as that

of our employees, suppliers, Contractors, Clients or Platform.

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â—Ź For legitimate business interests, including but not limited to addressing personal data requests and complaints you make and to manage our Website and Platform.

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â—Ź For appropriate legal reasons, such as complying with legal and regulatory requirements, carrying out background checks (KYC processes), or responding to requests from public and government authorities and regulators.

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â—Ź For internal business reasons, such as for commercial, statistical and/or market research purposes.

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● For marketing and events-related communications: (i) when you consent to said communication; (ii) when it is in Ontop’s legitimate interest; and (iii) increasing efficiency in the fulfillment of our legal and contractual duties.

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â—Ź For reasons you have previously consented to.

6. Who do you share my Personal Data with? 📲

● Vendors and Service Providers. We may share your Personal Data with our  suppliers, vendors and/or service providers, when in connection with our business and legitimate interests. 

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â—Ź Merger or Acquisition. We may disclose Personal Data collected about you and/or other information you provide us to a third party who acquires any part of our business, whether such acquisition is by way of merger, consolidation, divestiture, spin-off, or purchase of all or a substantial portion of our assets.

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â—Ź Disclosure Permitted by Law. We may disclose Personal Data collected about you and/or other information you provide us to law enforcement authorities, government or public agencies, officials, regulators, among others.

7. Do you use Cookies and other web technologies? 🍪

Our Website uses persistent and temporary Cookies and similar technologies. Information collected through the use of Cookies includes, but is not limited to user login information and time zone setting. When you visit our Website, you will receive a pop-up to consent with the collection of Cookies.

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We also use analytics tools to help us get a better understanding of how visitors use our Website and Platform.

8. How does Ontop protect my Personal Data?🏰

The security of your Personal Data is extremely important to us. We take the appropriate steps to protect the information you provide us from loss, misuse, unauthorized access or disclosure, alteration and destruction, both against external and internal threats. We adopt all measures and make use of technology trusted by the industry to provide as much security for your Personal Data as possible.

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Where we have given you a password or other login information which enables you to access our Platform, you must keep your password secret and not share your password or login information with anyone else.

9. How does you process the Personal Data of minors and other sensitive information?👶

Our Platform and Services are not directed to minors under the age of 18. We perform age verification on users that access our Platform, and if you are under the age of 18, you will be unable to contract our Services.

10. I have another Privacy question, where should I ask? 🙋

If you have more questions about Ontop’s Privacy Policy or privacy practices, would like to contact our Data Protection Officer, or would like to submit a complaint, you can contact us at privacy@getontop.com (please write "Privacy Policy Issue" on the subject line) or fill out the form at our Ontop Privacy Center. You can also reach out to us via snail mail at: Ontop Holdings Inc., 251 Little Falls Drive, Wilmington, New Castle County, Delaware, 19808.

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Ontop takes your privacy questions seriously. A dedicated team reviews your inquiry to determine how best to respond to your question or concern, including those inquiries received in response to an access or download request. In most cases, all substantive contacts receive a response within 30 days. In other cases, we may require additional information or let you know that we need more time to respond.