Global Privacy Notice

Effective Date: February 1, 2021
Last Updated: February 1, 2023

I. Introduction

Appropriately managing and safeguarding personal data is fundamental to OM Digital Solutions Corporation and its family of companies’ (“We” or “OMDS”), core values, external business partners, employees, and customers. This Privacy Notice explains how we collect, use and share information, including your personal data, when it’s collected through this website and/or mobile application, linked products, applications, services, websites, sub-sites, widgets, interactive features, forms, mobile site(s) and social media pages offered, owned, or operated by OMDS (the “Site(s)”).

If we make changes to this Privacy Notice, we will notify you by revising the Effective Date above and, in some cases, we may provide you with more prominent notice (such as sending you a notification or providing you with other disclosures within or in connection with the provision of the Sites). Your access to and use of the Site(s) means you agree to the terms in this Privacy Notice. We encourage you to refer to this Privacy Notice periodically so that you understand our current privacy practices.

This Privacy Notice Explains:

• I.Introduction
• II.Who You Should Contact
• III.Types Of Information We Collect And Use
• IV.Why We Collect And Use Information
• V.Additional Ways We May Collect and Share Your Information
• VI.How Long We Will Keep Your Personal Data
• VII.Our Use Of Information Technology
• VIII.Security
• IX.International Transfers Of Personal Data
• X.Promotional Emails
• XI.Information Applicable To Residents Of the United States
• XII.Personal Data Subject To European Privacy Laws
• XIII.Personal Data Subject To Japanese Privacy Laws

II.Who You Should Contact

If you have any questions about this Privacy Notice, please contact us by using the following information:

Contact us within the Americas:

Attn: OMDS Data Privacy
OM Digital Solutions Americas, Inc.
306 S New Street, Suite 110 Bethlehem, PA 18015, U.S.A
email@om-digitalsolutions.com
1-800-622-6372 Monday-Friday, 6am-2pm ET

Contact us within Europe, Middle East and Africa:

Attn: Data Protection
OM Digital Solutions GmbH
Willy-Brandt-Strasse 23, 20457 Hamburg, Germany
data-protection@om-digitalsolutions.com

Contact us in Asia:

Attn: Data Protection
49-3, Takakura-machi, Hachioji-shi, Tokyo, 192-0033, Japan
https://www.om-digitalsolutions.com/ja/privacy_management/privacy_contact_ja.html

Or, follow the instructions in the “contact us” section within the Site(s), if applicable.

III. Types Of Information We Collect And Use

OMDS collects certain information, including personal data, from you and about you. The term “personal data” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to a natural person (you). OMDS’ goal is to limit the information we collect to the information needed to support our business. Not all categories may be collected about every individual.

Below is a summary of the categories of personal data we may collect, where we get it, why we collect it, and with whom we may share it:

IV. Why We Collect And Use Information

Below are examples of ways we use your information collected for product and service fulfillment; marketing, promotions, and advertising; internal operations; fraud prevention, security and compliance; and payment processing, as referenced above:

Product and Service Fulfillment

• To complete, fulfill, manage, and communicate with you about your transactions;
• To establish and service your online profile/account on the Site(s);
• To provide you with customer service and alert you to product or shipping information;
• To enable the provision of services, such as training events, repair of products, and other events or services;
• To administer loyalty programs; and
• Respond to inquiries, requests, complaints, questions, comments.

Marketing, Promotions & Advertising

• To deliver information about our products, services, and promotions (e.g., email, third-party sites or applications, and mobile devices);
• To provide interactive features on the Site(s) (e.g. product ratings and reviews, comments, blogs, real-time offers and location-based offers);
• To identify product preferences and shopping preferences (e.g. services and promotions of possible interest) and;
• To administer contests, sweepstakes, promotions, and surveys.

Internal Operations

• To improve the effectiveness of the Site(s), services, merchandise assortment, and customer service;
• Quality control and training;
• To confirm contractual requirements;
• To conduct research and analytics related to our operations; and
• To perform other logistics and operations activities as needed.

Fraud Prevention, Security and Compliance

• To protect our assets and prevent fraudulent transactions;
• To validate credentials and authenticate customers and other users when logging into your online profile, and/or applications;
• To protect the security and integrity of our services and our data; and
• To assist law enforcement and respond to legal regulatory inquiries.

Payment Processing

• To process your payments and address your order inquiries and requests.

OMDS does not rent, lease, or otherwise sell your Personal Data.

V. Additional Ways We May Collect And Share Your Information

In addition to the methods enumerated above, OMDS may collect and share information, including your personal data, through the following methods:

Information From Other Sources

• We may receive your updated shipping information from a third-party provider.
• We engage with current and prospective customers through multiple internet marketing channels and social media services (e.g., Facebook, Instagram, Twitter, Tiktok, Wechat, Weibo). If you contact us on one of our internet marketing channels, request customer service via social media or otherwise direct us to communicate with you via social media, we may contact you via direct message or use other internal or social media tools to interact with you. In these instances, your interactions with us are governed by this Privacy Notice as well as the privacy notice of the social media platform you use. If you choose to access, link to, or log-in to our Sites or internet marketing channels or otherwise communicate with us through a third-party social media service, you are granting us permission to access and use the information that you post or store on the applicable social media service in accordance with the privacy notice of that service and the privacy settings that are applicable to your account, and to store the user name and password you use to log-in to the applicable social media service. By accessing or logging into our Sites or internet marketing channels via a social media service, any information you provide to us may also become accessible to that service, subject to that service’s privacy notice. For additional information and more details on how you can manage the information provided to us by these social media services, please review the privacy settings applicable to your account with the applicable social media service. We do not control, and are not responsible for, the privacy practices of such services. Please consult the privacy notice of such services for additional information.
• We may also share aggregated or anonymize information, which cannot reasonably be used to identify you.
• We participate in consortiums to share information or match customer data. When shared, this information is de-identified or anonymized.
• We may receive various types of information, including identification information, contact information, and transactional information, from our service providers, vendors, and family of companies. We may combine the personal data and non-personal data collected online and offline, including information collected from third parties to provide you with advertisements we think you will find interesting.

Business Transfers

Unless otherwise prohibited by law, if OMDS merges with, acquires or is acquired by another business entity, it may share your information with any successors to all or part of its business. This may include an asset sale, corporate reorganization or other change of control. If OMDS or any of its subsidiaries sold to or are otherwise acquired by a third party, all OMDS’ data assets will become the property of the acquiring party. Such a party will be subject to the consent(s), opt-outs or other customer conditions on data. A change in data ownership may or may not include a notice on the Site(s).

Third Party Marketing

Unless prohibited by law, including the European Privacy laws, as defined in Section XII, we may share your information with third parties that provide products or services we believe may interest you. These third parties may also share your information with others. These third parties may use your information for their own marketing purposes or the marketing purposes of others. This may include the delivery of internet-based advertising.

VI. How Long We Will Keep Your Personal Data

We will retain your Personal Data only as long as necessary to provide you with the products, services and programs you request, our essential business purposes, such as maintaining the performance of the services and programs, making data-driven business decisions about new features and offerings, complying with our legal obligations and resolving disputes. When we have no justifiable business need to process your Personal Data, we will either delete or anonymize it.

The criteria, used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide services or programs to you (for example, for as long as you have a profile/account with us or keep using the services/programs);
• Whether there is a legal obligation to which we are subject; or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statues of limitations, litigation or regulatory investigations).

VII. Our Use Of Information Technology

This section describes the various types of technologies we may use when you interact with our Site(s), and your choices regarding those technologies:

Cookies, Pixel Tags, and Flash Cookies

We collect certain information, including personal data, by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs, and web beacons. Cookies are small text files that websites send to your computer or other connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize when you return to the Site(s). They also help us provide a customized experience and enable us to detect certain kinds of fraud. The types of technology used by OMDS may change over time as technology evolves. Some of these technologies are essential for the provision of the Site(s), such as account access/authentication. To learn more about the cookies we use, click here.

Website Optimization Services

OMDS shares information with Google Analytics and other optimization services to understand and optimize website performance and enhance site usability for users. These tools run in the background of our sites analyzing site usage information and then return reports to us through an encrypted connection. They are required to maintain data securely and confidentially and are not permitted to share data collected with parties other than OMDS. Credit card, passwords or other sensitive information is not collected through these optimization services. In addition, these services may associate and group session visits to our website from various browsers and devices. To learn more about Google Analytics, including options for opting out and/or managing the ads you may see online please visit: www.google.com/policies/privacy/partners.

Interest-Based or Online Behavioral Advertising

OMDS uses third-party advertising companies to serve interest-based advertisements. These companies compile information from various online sources to match user profiles with ads we believe will be most relevant, interesting and timely based on that users profile.

Social Network & New Tech Advertising Programs

OMDS has relationships with several social networks. These companies have specific interest-based ads programs that match people that have shown an interest in OMDS products and services through our Site(s) or other services within their profiles (such as on Facebook) and platforms (such as Facebook and Google). This matching allows us to deliver relevant, interest-based ads on those companies’ networks.

Do Not Track

OMDS does not currently recognize and process Do Not Track signals from different web browsers. For more information on Do Not Track please visit http://www.allaboutdnt.org/.

VIII. Security

OMDS is committed to maintaining appropriate organizational, technical, and physical controls to protect the personal data entrusted to us. These controls protect personal data from anticipated threats and hazards as well as unauthorized access and use. OMDS will strive to provide security that is proportional to the sensitivity of the personal data being protected, with the greatest effort being focused on protecting sensitive personal data, like financial data, that could result in substantial harm or inconvenience if it got into the wrong hands.

IX. International Transfers Of Personal Data

Your information, including your personal data, will be submitted to servers managed by OMDS and/or its service providers/sub processor(s). By accessing or using the Site(s) or otherwise providing information to us, you consent to the processing and transfer of information, including your personal data, to the European Union, Japan, United States and/or any other location where the OMDS group operates which are described at https://www.om-digitalsolutions.com/en/common/support-launchinfo_en.html.

X. Promotional Emails

If we send you any promotional emails, and you no longer would like to receive such emails, please follow the “unsubscribe” instructions on those emails, if available. Your email address will be removed from our marketing list. Please allow us a reasonable period of time in order to satisfy your request.

XI. Information Applicable To Residents Of the United States

(a) Information about Minors

OMDS is strongly committed to preserving online privacy for all of our Site(s) visitors, including children. OMDS’ policy is not to collect any personal data about children under 13 years old. OMDS’ services are offered to customers who are the age of 13 years and above. No programs, services or offerings are intended for children under the age of 13. Furthermore, we may restrict entries to any contests, sweepstakes or promotions to entrants who are at least 18 years of age.

Minors under 18 years of age may have the Personal Information that they provide to us through the Site deleted by sending an email requesting deletion to email@om-digitalsolutions.com. Please note that, while we make reasonable efforts to comply with such requests, deletion of your personal data does not ensure complete and comprehensive removal of that data from all systems.

(b) California Residents

California residents have certain additional rights regarding our use and disclosure of personal information in accordance with the California Consumer Privacy Act of 2018 (the “CCPA”). For purposes of this section XI only, the term “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, as further defined by the CCPA.

• Collection of Personal Information
  We have collected in the preceding twelve (12) months, the following category of Personal Information from you. For examples of the precise information we have collected, please refer to the “Types Of Information We Collect And Use” and “Additional Ways We May Collect And Share Your Information” sections above:

  Category	Examples
  A. Identifiers	Real name, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, company name, title or other similar identifiers.
  B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Name, address, and telephone number.
  C. Internet or other electronic network activity information.	Browsing history, search history, and information regarding a consumer’s interaction with an internet website.
  D. Electronic, visual, or similar information	Videos and photographs containing facial images and appearances.

  We have collected each category of Personal Information listed above from you and the third-party sources described in the “Types Of Information We Collect And Use” and “Additional Ways We May Collect And Share Your Information” sections above.

• Use of Personal Information
  We have collected each category of Personal Information listed above for the business or commercial purposes described in the “Why We Collect And Use Information” section above.
• Sharing or Disclosure of Personal Information
  We may share each category of Personal Information listed above with the third parties as described in the “Types Of Information We Collect And Use” section above.
• Sales of Personal Information
  We have not sold any category of Personal Information described above in the preceding twelve (12) months.
• Your Rights and Choices under the CCPA
  The CCPA provides specific rights regarding Personal Information to consumers who are residents of California. The following parts of this section describe your rights and explain how to exercise those rights under the CCPA.
  • (i)Right to Access Specific Information
    You have the right to request that we disclose certain information to you about our collection, sharing, disclosure or use of your Personal Information over the preceding twelve (12) months from the time of your request. Once we receive and confirm your verifiable consumer request, we will disclose to you any or all of the following information: (1) the categories of Personal Information we collected about you; (2) the categories of sources from which the Personal Information is collected; (3) the business or commercial purpose for collecting or selling the Personal Information; (4) the categories of third parties with whom we sell or share Personal Information; (5) the categories of Personal Information sold by each third party who sold Personal Information; (6) the categories of Personal Information disclosed for business or commercial purposes; and (7) the specific pieces of personal information we have collected about you. To submit a request for this information, you may email us at email@om-digitalsolutions.com.
  • (ii)Right to Request Deletion
    You have the right to request that we delete any of your Personal Information that we have collected from you and retained, subject to certain exceptions. Upon receiving and confirming your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception set forth in the CCPA applies.
  • (iii)Opt-Out Rights
    We have not sold any category of Personal Information described above in the preceding twelve (12) months.
  • (iv)Non-Discrimination
    We will not discriminate against California residents for exercising any of their rights under the CCPA. Moreover, unless permitted by the CCPA, we will not: (1) deny you goods or services; (2) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (3) provide you with a different level or quality of goods or services; or (4) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
  • (v)Exercising Rights under the CCPA
    To exercise your rights under the CCPA to access or delete your Personal Information as described above, please submit a verifiable consumer request to us by emailing email@om-digitalsolutions.com.
    Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
    The verifiable consumer request must: (1) provide sufficient information that allows us to reasonably verify that you are the person whose Personal Information we have collected or an authorized representative thereof; and (2) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond thereto.
    Shortly after you (or your agent) submit a request, we will contact you (via email at the email address provided during submission of your request) with instructions on how to verify the request before we fulfill it. We will verify your identity by asking you to log in to your account if you have one with us. Or if you do not, we may ask for your email address, the order number of a recent order you placed with us or the last four digits of a credit or debit card used on our Site(s). We will aim to complete your requests as soon as reasonably practicable and consistent with any applicable laws.
    If you have an account with us, you may also see certain personal information (such as certain profile and transaction information) directly through your account profile page after logging in to a Site. Please note that changes you make on your account profile page through one of our Sites may not always be reflected on other Sites operated by us.

(c) Shine the Light Law - Direct Marketing

You have the right to request information from OMDS once per calendar year regarding the manner in which OMDS shares certain categories of your personal information with third parties, for the third parties' direct marketing purposes. California Civil Code § 1798.83 provides you with the right to submit a request to OMDS at its designated address and receive the following information:

• The categories of personal information OMDS’ disclosed to third parties for the third parties' direct marketing purposes during the preceding calendar year;
• The names and addresses of third parties that received such information; and
• If the nature of a third party's business cannot be reasonably determined from the third party's name, examples of the products or services marketed.

You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually. OMDS’ designated email address for such a request is email@om-digitalsolutions.com.

To learn more about managing your privacy and to know your choices concerning interest-based ads, you may visit the Network Advertising Initiative's opt-out page at http://www.networkadvertising.org/managing/opt_out.asp or www.aboutads.info/choices.

XII. Personal Data Subject To European Privacy Laws

If you are located in the European Union, the United Kingdom, Switzerland and/or your personal data is otherwise subject to the General Data Protection Regulation or comparable European Data Protection Legislation (collectively referred to as “European Privacy Laws”), this section provides additional information about your rights and how OMDS processes your personal data.

OMDS is the controller of personal data submitted by you or otherwise collected when you use the Site(s). Please note, however, that OMDS is not the controller of third-party data you may submit to the Site(s). We process such information within the Site(s) solely in the processor’s role and, depending on the scope of your activity, you may be the data controller.

Rights to Control Your Personal Data

You may have certain rights with regard to your personal data under European Privacy Laws. If you would like to request a copy of your personal data being held by us, request that your personal data is deleted, request to update and/or correct your personal data, or request that we provide a copy of your personal data to another data controller, please contact us. We will aim to respond to your request within one calendar month of receipt of your request. Where we are unable to do so within the calendar month, we will notify you of the soonest practicable time within which we can respond to your request (and within three months from the date of your request). There are certain exemptions and restrictions of these rights under the European Privacy Laws that enable personal data to be retained, processed or withheld from access and we will inform you of these restrictions if they apply. We use your Personal Data as described in the chart above.

Sharing your personal data

We share your personal data with third parties to help us use your personal data, as described in the Privacy Notice.

Tracking Tools (“Cookies”)

We use cookies as described in our Cookie Notice. You may choose to block or delete cookies, but doing so will cause the Site(s) to not operate correctly.

Contact us

You may access, download, change, or modify your personal data by contacting us. You may also exercise your right to prevent us from sharing your personal data at any time by contacting us as described above in the “Who You Should Contact” section.

Submit a Complaint to a Supervisory Authority

You have the right at all times to submit a complaint to a data protection supervisory authority, in case you feel that the processing of your personal data, as described in this Notice, infringes with the law. You may find a list of the supervisory data protection authorities in Europe here: https://edpb.europa.eu/about-edpb/board/members_en.

Legal Basis

OMDS has the following legal basis for processing your Personal Data:

Type of Personal Data	Legal Basis
Information you provide to us	OMDS exercising its rights and performing its obligations in connection with any contract we make with Controller (Article 6 (1) (b) General Data Protection Regulation). Compliance with OMDS’ legal obligations (Article 6 (1) (c) General Data Protection Regulation).
Information we collect automatically	Legitimate interests pursued by OMDS (Article 6 (1) (f) General Data Protection Regulation). OMDS has assessed that these legitimate interests are not overridden by the data protection interests or fundamental rights of any individuals. Compliance with OMDS’ legal obligations (Article 6 (1) (c) General Data Protection Regulation).

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us at data-protection@om-digitalsolutions.com.

XIII. Personal Data Subject To Japanese Privacy Laws

You may request, pursuant to the Act on the Protection of Personal Information (Japanese Law), the disclosure correction, deletion or other measures regarding the personal data provided hereby. Please see “Personal Information Inquiry” for matters concerning procedures for consenting to “requests for disclosure” on the service desk.
https://www.om-digitalsolutions.com/ja/privacy_management/privacy_contact_ja.html

History of revision