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Privacy Policy

Effective July 1, 2018

 

Thank you for visiting Obo. Obo respects your privacy. We value transparency and want you to know exactly what we do with your personal information. This page maps out what personal information we collect, what we do with it, and your choices and rights.

By using any of Obo’s websites or online services (including Obo Product Suite and related applications and systems), you confirm you have agreed to the Terms of Service and read and understood this Privacy Policy and our Cookie Policy.

1. Some key terms

In our Privacy Policy, when we refer to Users, we mean our customers who use Obo Product Suite (including trial participants), Obo services (such as customer support), and all visitors to our websites. All users, visitors, and customers are Users.

2. How does this Privacy Policy apply?

This Privacy Policy describes what we do with personal information that we collect and use for our own purposes (that is, where we control the use of that information), such as your account information (in the case of Obo Product Suite customers or trial participants) and information about how you use and interact with Obo services, including information you submit to customer support.

We use cookies and similar technologies. Our Cookie Policy describes what we do.  

3. Personal information we collect

We collect a variety of personal information regarding you or your device. This includes the following:

  • Information you provide to create an Account, specifically your email address, first name and last name. If you purchase an Obo Product subscription, we receive a portion of your payment information from our payment processor (such as the last four digits, the country of issuance and the expiration date of the payment card) and we ask you to select your jurisdiction.
  • Your marketing preferences.
  • The emails and other communications that you send us or otherwise contribute, such as customer support inquiries or community posts (e.g., to customer message boards or forums). Please be aware that any information that you post on public parts of our sites is available to others.
  • Information you share with us in connection with surveys, campaign responses, or promotions.
  • Information from your use of the Obo website and on-line software suite. This includes: IP addresses, preferences, web pages you visited prior to coming to our sites, information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), information about how you interact on-line with Obo (such as timestamps, clicks, scrolling, browsing times, searches, transactions, referral pages, load times, and problems you may encounter, such as loading errors).
  • Information we get from our partners to support marketing campaigns, improve our services, and better monitor our online marketing campaigns, such as details about when an Obo partner shows you one of our campaigns or promotions on or via its site or advertising platform.
  • Other information you submit to us directly or through Third Party Services if you use a Third Party Service to create an Obo account (based on your privacy settings with such Third Party Service).

4. How we collect personal information

We obtain personal information from various sources in three primary ways:

  • You provide some of it directly (such as by registering for an Account).
  • We record some of it automatically when you use Obo Product Suite or Obo websites (via technologies like cookies).
  • We receive some of it from third parties (such as when you register for an account using a Third Party Service or when you make payments to us using our payment processor).

We’ve outlined this in more detail below.

a. Personal information you provide

When you use our Services, we collect information from you in a number of ways.  

  • We ask you to provide your name and email address to register and use an Obo free trial or to set up and use an Obo account.
  • We maintain your marketing preferences and the emails and other communications that you send us or otherwise contribute, including customer support inquiries or posts to online communities or forums.
  • You may provide us with information in other ways, such as responding to surveys, submitting a form, or attending an event.

We may require you to provide information for specific contractual or legal reasons. For example, we may ask you to select your jurisdiction when you sign up for Paid Services to determine tax implications and requirements. We will inform you when this information is required, and we will let you know the consequences of failing to provide it. For example, you may not be able to use our Services if that information is necessary to provide the service or if we are legally required to collect it.

b. Personal information obtained from your use of our Services

When you use our Services, we collect information about your activity on and interaction with the Services, such as your IP address(es), your device and browser type, the web page you visited before coming to our sites, what pages on our sites you visit and for how long and identifiers associated with your devices. If you’ve given us permission through your device settings, we may collect your location information in our mobile apps.

We collect some of this information automatically using cookies and similar technologies when you use our Services and sites. You can read more about our use of cookies in our Cookie Policy. Some of this information is similarly collected automatically through your browser or from your device.

c. Personal information obtained from other sources

If you sign up for Paid Services and use a credit card for payment, we obtain limited information about your payment card from our payment processor, such as the last four digits, the country of issuance, and the expiration date.

5. How we use your personal information

We use the personal information we obtain about you to:

  • Provide Services. Create and manage your Account, provide and personalize our Services, process payments, and respond to your inquiries.
  • Communicate with you. Communicate with you, including sending you emails about your Obo-related transactions and any Service-related announcements (e.g., maintenance updates, planned downtime, etc.).
  • Conduct surveys. Send surveys to you, with your permission.
  • Promote Services. Promote our Services and send you marketing communications about products, services, offers, programs and promotions of Obo and our partners and measure the success of those campaigns. For example, we may send different marketing communications to you based on what Obo Services you use or other information we hold about you.
  • Customize the Services. Provide you with customized services. For example, we may use your location information to display accurate date and time information. We also use cookies and similar technologies for this purpose.
  • Improve our Services. Analyze and learn about how you access and use Obo Services so that we can evaluate and improve our Services (for example, by developing new products and services or tailoring our communications) and monitor and measure the effectiveness of our marketing and promotions. We do this based on anonymous or aggregated information which does not focus on you individually.
  • Ensure Security. Ensure the security and integrity of our Services.
  • Manage third-party relationships. Manage our vendor and partner relationships.
  • Enforce Terms of Service. Enforce our Terms of Service and other legal terms and policies.
  • Protect rights and property. Protect our and others’ interests, rights and property (e.g., to protect our Users from abuse).
  • Comply with law. Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts, and law enforcement requests.

We process your personal information for the above purposes when:

  • Consent. You have consented to the use of your personal information in a particular way. Note that you can change your mind at any time and we will update how we use your information.  
  • Performance of a contract. We need your personal information to provide you with Services and products requested by you, and to respond to your inquiries. We need this information s that we can perform our contract with you or take steps at your request before entering into one. For example, we need your email address so you can sign in to your Obo account.
  • Legal obligation. We have a legal obligation to use your personal information, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.
  • Legitimate interests. We have a legitimate interest in using your personal information. In particular, we have a legitimate interest in the following cases:
    • To operate the Obo business and provide you with tailored communications.
    • To analyze and improve the safety and security of our Services – we do this as it is necessary to pursue our legitimate interests in ensuring Obo is secure, such as by implementing and enhancing security measures and protections and protecting against fraud, spam, and abuse.
    • To provide and improve the Services, including any personalized services – we do this as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to our Users on a sustained basis.
    • To share your personal information with other Obo group companies that help us provide and improve the Services.
    • To anonymize and subsequently use anonymized information.
  • Protecting you and others. To protect your vital interests, or those of others. 
  • Others’ legitimate interests. Where necessary for the purposes of a third party’s legitimate interests, such as our partners who have a legitimate interest in delivering requested information and/or services to you and monitoring and measuring its effectiveness.

6. How we share your personal information

We share personal information in the following ways:

  • Business partners.  We may share personal information with business partners. For example, we may share your personal information when our Services are integrated with their Third Party Services, but only when you have been informed or would otherwise expect such sharing.
  • Service providers. We share personal information with our service providers that perform services on our behalf. For example, we may use third parties to help us provide customer support, send marketing and other communications on our behalf, or assist with data storage.
  • Process payments. We transmit your personal information via an encrypted connection to our payment processor.
  • Following the law or protecting rights and interests. We disclose your personal information if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property or interests (such as enforcing our Terms of Service) or prevent fraud or abuse of Obo or our users. In particular, we may disclose your personal information in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements.
  • Advertising. We share personal information with third parties so they and we can provide you with tailored advertising and measure and monitor its effectiveness. For example, we may share your pseudonymized email address with a third-party content platform on which we advertise to avoid serving Obo ads to people who already use Obo.
  • Business transfers. If we’re involved in a reorganization, merger, acquisition, or sale of some or all of our assets, your personal information may be transferred as part of that deal.

7. Your rights and choices

Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to access, update, change, or delete your personal information.

You can access, update, change, or delete your personal information either directly in your Obo on-line account or by contacting us at legal@obo.pm to request the required changes. You can exercise your other rights (including deleting your Account) by contacting us at the same email address.

You can also elect not to receive marketing communications by changing your preferences in your Account or by following the unsubscribe instruction in such communications (generally provided in the footer area of those communications).

Note that there may be a delay, for technical reasons, in deleting your personal Information from our systems when you request that we delete it. We also will retain personal Information to comply with the law, protect our and others’ rights, resolve disputes, or enforce our legal terms or policies, to the extent permitted under applicable law.

You may have the right to restrict or object to the processing of your personal information or to exercise a right to data portability under applicable law. You also may have the right to lodge a complaint with a competent supervisory authority, subject to applicable law.

Additionally, if we rely on consent for the processing of your personal information, you have the right to withdraw it at any time for no charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.

Our Cookie Policy explains how you can manage cookies and similar technologies.

8. How we protect your personal information

Our security team is dedicated to keeping your personal information safe. We maintain administrative, technical, and physical safeguards to protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of, the personal information in our possession.

9. How we retain your personal information

We retain personal information regarding you or your use of the Services for as long as your Account is active or for as long as needed to provide you with the Services. We also retain personal information for as long as necessary to achieve the purposes described in this Privacy Policy, for example, to comply with our legal obligations, to protect us in the event of disputes, to enforce our agreements, and to protect our and others’ interests.  

The exact length of time for which we keep your personal information may vary depending on the nature of the information and why we need it. Factors will include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made, whether the personal information has been aggregated or pseudonymized, and other relevant criteria.

You may delete your Account by contacting us at legal@obo.pm and Obo will delete any personal information it holds about you (unless we must retain it for the purposes set out in this Privacy Policy).

Please note that in the course of providing Obo Services, we collect and maintain aggregated, anonymized, or de-personalized information which we may retain indefinitely.

10. Data transfers

Personal information that you submit through the Services may be transferred to countries other than where you live, such as, for example, to our servers in the U.S. We also store personal information locally on the devices you use to access the Services.

Your personal information may be transferred to countries that do not have the same data protection laws as the country in which you first provided your personal information.

We rely upon a number of means to transfer personal information which is subject to the European General Data Protection Regulation (“GDPR”) in accordance with Chapter V of the GDPR.  These include:

  • Privacy Shield. We transfer, in accordance with Article 45 of the GDPR, personal information to companies that have certified their compliance with the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks (each individually and jointly, the “Privacy Shield”), including Obo, Inc.
  • Standard data protection clauses. We may, in accordance with Article 46 of the GDPR, transfer personal information to recipients that have entered into the European Commission approved contract for the transfer of personal data outside the European Economic Area.  
  • Other means. We may, in accordance with Articles 45 and 46 of the GDPR, transfer personal information to recipients that are in a country the European Commission or a European data protection supervisory authority has confirmed, by decision, offers an adequate level of data protection, pursuant to an approved certification mechanism or code of conduct, together with binding enforcement commitments from the recipient to apply the appropriate safeguards, including as regards data subjects’ rights, or to processors which have committed to comply with binding corporate rules.

11. Privacy Shield 

Obo, Inc has certified its compliance to the Privacy Shield.

Obo is committed to treating personal information received from the European Economic Area and Switzerland pursuant to the Privacy Shield Frameworks in accordance with the applicable Principles. You can find our certification here and you can learn more about the Frameworks and Principles by visiting https://www.privacyshield.gov/.

Our accountability for personal information we receive under the Privacy Shield and subsequently transfer to a third party is described in the Privacy Shield Principles.

If you have a question or complaint you believe to be within the scope of our Privacy Shield certification, please contact us first at legal@obo.pm, or using the contact details in the “How to contact us” section below. We’ll respond within 45 days.

For any complaints that we can’t resolve directly, JAMS is the independent organization responsible for reviewing and resolving complaints about our Privacy Shield compliance. You can contact JAMS free of charge at https://www.jamsadr.com/eu-us-privacy-shield. JAMS is an alternative dispute resolution provider based in the U.S.

If your concern still isn’t addressed by JAMS, you may be entitled to a binding arbitration under the Privacy Shield Principles. For purposes of enforcing compliance with the Privacy Shield, Obo, Inc. is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission.

12. Updates to this Privacy Policy

We will update this Privacy Policy occasionally to reflect changes in technology, law, our business, or any other reason we determine is necessary. When we make changes, we will update the “Effective Date” at the top of the Privacy Policy. If we make material changes to our Privacy Policy or the ways we process personal information, we’ll notify you (for example, by posting a notice of the changes on our Services or sites before they take effect or by directly sending you a notification).

We encourage you to check back periodically to review this Privacy Policy to ensure you understand your relationship with us, including the ways we process your personal information.

13. How to contact us

If you have questions, comments, or complaints about this Privacy Policy or our privacy practices or if you would like to exercise your rights and choices, please email us at legal@obo.pm, or write to us at the addresses below:

Obo, Inc.
Attention: Legal – Privacy
940 Emmett Ave. Suite 120
Belmont, CA 94102
United States