Table of Contents
OSG Privacy Policy
Last Modified: October 2, 2024
OSGTM and its corporate affiliates and subsidiaries (“OSG,” “we,” “us” or “our”) respect the privacy of the information you have entrusted to us. This Privacy Policy (“Policy”) describes the types of Personal Information (as defined below) we collect, how we use the information, with whom we may share it, and the choices available to you which apply to the online collection of Personal Information by OSG through our website at osgconnect.com and any other platforms where you provide information to us (the “Sites”) along with other interactions with us through telephone, email or otherwise. By using our Sites and services (collectively, the “Services”), you acknowledge you have read and understand the terms and conditions of this Policy. If you do not agree to the terms and conditions of this Policy, please do not use our Services or access our Sites.
Our use of information we collect as a service provider or processor for our customers is limited by the restrictions placed on that information, if and as applicable, by our clients and their own privacy policies. You can learn more about how your information is collected and used by our clients by reviewing the privacy policies of the businesses that you engage with.
If another OSG Service sets forth a separate or additional privacy policy or statement, that separate or additional policy shall apply in connection with your use of that Service.
We will use Personal Information about you only for the purposes and in the manner set forth below, which describes the steps we take to ensure the processing of Personal Information is in compliance with applicable data protection law, including if and when applicable, California’s Consumer Privacy Act (“CCPA”) and the European Union’s General Data Protection Regulation (“GDPR”).
When you sign up with an account with us, we may collect and use your Personal Information on behalf of our partners and third-party services providers to facilitate the provisioning of the Services. The Personal Information processed in such cases is subject to our Policy and laws, such as Gramm-Leach Billey Act, and may be excluded from some comprehensive state privacy laws. Federal law requires our partners to provide notice to end-users to explain what Personal Information they collect, how they share it, and how end-users may limit our partners’ sharing of information. The privacy practices of our partners are subject to their privacy notices, which we strongly suggest you review. We are not responsible for our partners’ information practices or privacy notices but may publish the notices and process data subject requests as part of the Services.
Information We Collect
We collect the following categories of information from and about you:
Personal Information You Give to Us
Personal Information is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with a particular individual. We may ask you to provide your Personal Information voluntarily as you interact with us on the Sites, or when you speak with us by telephone or communicate by email. Personal Information may include, but is not limited to, your:
- Email address
- First name and last name
- Phone number
- Mailing address
- Government identifiers
- Financial information
The Personal Information we collect, the basis of processing, and the purposes of processing are detailed below (see “Sharing and Disclosure of Information” section below). Sometimes, these activities are carried out by our partners or third party service providers that perform some or all the Services. The Personal Information we collect about you allows us to provide the Services and helps us manage our relationship with you, primarily by allowing us to respond to your questions, to improve your Site experience with our Services. We also collect information from you for potential staffing and employment purposes.
Information Collected Automatically
We may also collect data about you automatically through the Sites that may be Personal Information depending on the circumstances. Examples of such data include your IP address, device operating system type, browser type, domain, and other system settings. We may collect data about the website that you were visiting before you navigated to our Sites, and the website that you visit after you leave our Sites. We collect this data primarily to help us better understand our Sites’ traffic and to optimize our delivery of the Services to you.
Individuals in the European Union (EU)
For individuals in the EU, “Personal Data” has the meaning described in Article 4.1 of the GDPR. The following lawful bases support our processing activities under the GDPR:
| Data Source | Personal Data Collected | Basis of Processing |
| Representative of Prospective Customers | We collect your name, email address, job title, current organization, current industry, business interests, and phone number. | Necessary for Performance of a Contract. It is necessary to take steps at your request prior to entering into a contract (e.g., to respond to your queries and to provide you with further information; or where you have applied to become our customer). |
| Vendor and Supplier Representatives | We collect your name, email address, current company, current industry, business interests, and phone number. | Legitimate Interest. It is in our legitimate interests to store vendor/supplier related information so that we can refer to it (e.g., for our general recordkeeping and supplier relationship management). Our interests are not overridden by the interests or fundamental rights and freedoms of the data subject. |
| Those who wish to be included on our mailing list(s) | We collect your name, current company, and email address. | Consent. If you subsequently wish to withdraw your consent, you may do so at any time by clicking the “unsubscribe” link at the bottom of these communications. |
| Prospective Employees | We will collect your name, email address, phone number. | Necessary to take steps prior to entering into an employment contract; Consent. |
California Residents
The Personal Information about you that we collect includes information within the categories of data defined by California state privacy laws and provided below. Under the CCPA, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer or household. Personal Information does not include:
(1) de-identified or aggregated information;
(2) “publicly available information” that is lawfully made available from federal, state, or local government records; or
(3) information excluded from the CCPA, such as Protected Health Information or medical information that is subject to HIPAA, or other personal information covered by certain other privacy laws, such as the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, or California Financial Information Privacy Act, and the Driver’s Privacy Protection Act of 1994.
The following categories also represent the categories of Personal Information that we may have collected over the past 12 months. Inclusion of a category in the list below indicates only that, depending on the Services and products we provide you, we may collect some information within that category. It does not necessarily mean that we collect all information listed in a particular category for all our customers. We do not and will not sell Personal Information about you, as defined by CCPA.
| Categories of Personal Information Collected | Representative Examples of Data Elements | Sources of Personal Information | Purposes for Collecting | Categories of Third Parties with whom we may share this information |
| Contact Information | Full name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, telephone number. | You | To identify and communicate with you; to respond to your information requests; to send marketing or promotional information; and for our everyday business purposes. | Our affiliates and our third-party service providers who deliver our communications. |
| Prospective Employment Related Information | Full name, postal address, current company, Internet Protocol address, email address, telephone number, information about your employment that you voluntarily choose to share. | You | To take steps prior to entering into an employment contract | None |
| Internet or another similar network activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | Your device | To understand our Sites traffic and to optimize our delivery of the Sites | Third party data analytics providers |
| Geolocation data | Physical location. | Your device | Marketing Purposes | None |
Cookies and Tracking Tools
When you interact with the Sites and Services, certain information about your use is automatically collected. This information includes your device logs, Server Logs and other technologies used to gain access to our sites.
Much of this information is collected through cookies, web beacons, and other tracking technologies, as well as through your web browser or device (e.g., IP address, MAC address, browser version, etc.). We use cookies for the following purposes:
- Performance/Analytics: We use these cookies to analyze how the Sites and Services are accessed, used or are performing – including information about payment-related activities. We use this information to maintain, operate and continually improve the Sites and Services and to create products and services that may be of interest to our clients and end-users, and for analysis and other purposes.
- Site-Visit Recordation Technology: We use certain scripts and Site-visit recordation technology provided by third-party service providers, including those provided by Lead Intelligence, Inc. d/b/a Jornaya (“Jornaya”) and ActiveProspect, Inc. (including its TrustedForm service). We use these scripts/technology to record Site visits and independently document users’ consent to be contacted, including that those users have provided their respective “prior express consent” as required by the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time (“TCPA”).
- Advertising: Interest-based advertising is the collection of data across different websites and/or different devices for the purpose of tailoring advertising based on preferences or interests known or inferred from the data collected. We allow third parties who assist us in serving advertising regarding the Sites when you leave the Sites, to collect or receive information from our Sites and elsewhere on the internet and use that information to provide measurement services and targeted ads.
You may see our ads on other websites because we use third-party ad services. These ad services are a web analytics service and use cookies or other tracking technologies to help us analyze how users interact with and use the Sites and Services, compile reports on user activity, and provide other services related to activity and usage. The technologies may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website. The information will be transmitted to and stored and will be subject to the third party website’s privacy policies.
If you do not want to receive cookies, you may set your browser to reject them. However, if you turn cookies off, you may not have access to some of our Services and features. We also may allow third parties to issue cookies, pixels, web beacons and other tracking technologies on our Sites and Services to help us compile information regarding the operations of our Sites and Services.
You can learn more about ad serving companies and the options available to limit their collection and use of your information by visiting the websites for the Network Advertising Initiative, the Digital Advertising Alliance, AdChoices (for Canada) and the European Interactive Digital Advertising Initiative. Similarly, you can learn about your options to opt-out of mobile app tracking by certain advertising networks through your device settings and by resetting the advertiser ID on your Apple or Android device.
Because an industry-standard Do-Not-Track protocol has not yet been established, our information collection practices on our Sites and Services will continue to operate as described in this Policy regardless of any “Do Not Track” signals that may be sent by certain browsers. However, you may refuse to accept cookies to prevent tracking activities.
Use of Information Collected
We use the information we collect from or about you for the following purposes to:
- Provide, maintain, personalize, optimize and improve the Sites and Services, including for analytics related to our products and offerings and to provide information to our clients, end-users and others.
- Process and fulfill the transactions related to the Services.
- Comply with and enforce applicable legal requirements, agreements and policies.
- Establish and maintain the OSG accounts.
- Personalize your experience with regards to the Services.
- Maintain and enhance the safety and security of our Services and detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal.
- Send you marketing communications.
- Respond to your requests and inquiries.
- Advertise and market our products and the Services.
- Develop, maintain and improve our Services by using machine learning AI and risk modeling.
- For other legitimate business and operating purposes.
Sharing and Disclosing Information
We may share or disclose your information to the following categories of third parties and for the following reasons:
- To our affiliates, subsidiaries, partners, third-party service providers, agents or independent contractors who help us maintain or provide our Services and provide other operational and administrative services to us.
- We may share the information we collect about you during any reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all our assets.
- We may disclose the information we collect about you to law enforcement, government agencies, and other related third parties, to comply with the law, enforce our policies, or protect our or others’ rights, property or safety.
- We may share with other third parties only with your consent or direction to do so.
We disclose the Personal Information we collect about you for a business purpose to the following categories of third parties: our partners and third party service providers performing the Services or ancillary services, including website services, email services, and data analytics services.
We may change our ownership or corporate organization while providing the Sites and Services. We may transfer to another entity or its affiliates or service providers some or all information about you (including Personal Information) in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction.
Opt-Out
We offer you certain choices in connection with the opportunity to opt-out of marketing communications by clicking the “unsubscribe” link in email communications or by contacting us using the contact information provided below. Different states offer various opt-out rights, and we make it easy for you to submit an opt-out privacy request through privacy@osgconnect.com. We will process your request as soon as possible in accordance with applicable law, but please be aware that in some circumstances you may receive additional messages until the unsubscribe request is processed.
Additionally, we may send you information regarding our Services, such as information about changes to our policies and other notices and disclosures required by law. Generally, users cannot opt-out of these communications, but they will be primarily informational in nature, rather than promotional.
Third-Party Links
Our Sites may contain links to other sites, and may include our partners’ and third-party features such as apps, tools, widgets, and plug-ins. These online services and third-party features may operate independently from us. When you follow these links to those sites, the operators of those websites may collect information about you. The privacy practices of the relevant partners and third-parties, including details on the information they may collect about you, are subject to privacy disclosures of these parties which we strongly suggest you review. OSG does not review, control or monitor the practices, information or materials on any other websites, and is not responsible nor liable for the communications, information, content or materials from or the practices and policies (including without limitation privacy or data collection practices or policies) of any of those sites. If you have any questions about how these other sites use your information, you should contact them directly.
State Specific Disclosures
Rights Available to California Residents
Under the CCPA, residents of California are provided with certain rights regarding their Personal Information (as defined in the CCPA). The following section outlines these rights:
- Right to Know: You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- the Categories of Personal Information we have collected from you
- the business purposes for which such Personal Information was collected
- the Sources of Personal Information we have collected from you
- the specific pieces of Personal Information stored about you
- the categories of 3rd parties with whom we share Personal Information
- If we shared your Personal Information for a business purpose, the categories of Personal Information that each category of recipient obtained.
- Right to Request Deletion: You have the right to request deletion of your Personal Information that has been collected and retained from you subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete your Personal Information from our records, unless there is an applicable exception. You or an authorized agent registered with the California Secretary of State that you authorize to act on your behalf, may exercise the Rights twice in a 12-month period. Your verifiable request must include sufficient detail for us to understand, evaluate, and respond to it. It must also provide sufficient information that allows us to reasonably verify that you are the individual about whom we have collected Personal Information or an authorized agent representing the individual. Please note that in some cases we may need to obtain information from you as part of the verification process to verify your identity to a reasonable degree. We may require you to provide Personal Information as part of the verification process. For authorized agents, we may require a signed, written authorization, a notarized affidavit, or a valid power of attorney. We will only use this information for the purpose of verifying the requestor’s identity or authority.
To exercise these rights, please email us at privacy@osgconnect.com or complete the CCPA Request Form using the link below:
We will acknowledge your right to know or deletion request within 10 business days of receipt and provide information about how we will process the request. In many cases we will respond to your request within 45 days. In some cases, we may extend the time to respond for another 45 days. If this extension is necessary, we will give you notice and the reason that we need the additional time to respond.
If we are unable to verify your identity or your authority to make the request within 45 days, we cannot fully respond to you and may deny your request. We may in such cases elect to treat the deletion request as an opt-out request. For requests seeking specific pieces of information, we will treat it as a request for the disclosure of the categories of Personal Information about the consumer.
We retain records of your requests, including the request data, nature of the request, manner of submission, the response and any basis of denial for a period of 24 months.
We will not discriminate against you in terms of services, the level or quality of services, or pricing for exercising any of your CCPA rights. If there are excessive requests, we may charge a reasonable fee as permitted under the CCPA.
Right to Opt-Out of Data Sales for Nevada Residents
We do not sell your covered information, as defined by Section 603A.320 of the Nevada Revised Statutes. If you reside in Nevada, you have the right to submit a request to us at privacy@osgconnect.com regarding the sale of covered information. Please include “Nevada” in your email subject line and include the following information in your email: your name, Nevada resident address, and email address. We will respond within sixty (60) days of receiving your request.
Rights for Individuals Located in Colorado
If you are a Colorado citizen, you have rights regarding your Personal Information. Those rights and other state-specific information are described below:
- You have the right to request that we disclose to you, once in a 12-month period, the Personal Information we have collected about you. You also have the right to request additional information about our collection, use, disclosure, or sale of such Personal Information, which is also provided in this privacy statement.
- You also have the rights to request that we correct inaccurate Personal Information under certain circumstances, subject to a number of exceptions.
- You also have rights to request that we delete your Personal Information under certain circumstances, subject to a number of exceptions.
- You have the right to opt out of the sale of your data. Colorado law requires us to describe the categories of Personal Information we sell or share to third parties and how to opt-out of future sales. It is important to know that the definition of “sale” is very broad and the common flow of information for advertising and analytics may be considered a sale. OSG does not provide information that you might typically think of as Personal Information to third parties in exchange for money; however, under Colorado law, Personal Information may include unique identifiers, including things like IP addresses, cookie IDs, pixel tags, and mobile ad IDs. The law defines a “sale” broadly to include simply making such personal information available to third parties in some cases. In the last 12 months, when you access our online Services, we may let advertising and analytics providers collect IP addresses, cookie IDs, advertising IDs, and other unique identifiers, which may be collected along with device and usage data, and information about your interactions with our online Services and advertisements. We do not knowingly sell the Personal Information of minors under 16 years of age.
- You have the right to appeal our decision to refuse to act on a Colorado Privacy Act (CPA) data privacy request within a reasonable period after you receive our decision. To appeal our decision, forward your denial email to privacy@osgconnect.com for OSG’s privacy team to review your data subject request. Within 45 days, we will provide you with a written explanation of the reasons in support of our response. If you disagree with our explanation, you have the right to file a complaint with the Colorado Attorney General.
- You have the right to not be discriminated against for exercising any of your privacy rights.
To help protect your privacy and maintain security, we will take steps to authenticate your identity before granting you access to your Personal Information or complying with your request (except for a request to opt-out of sales). We may require you to provide any of the following information: your name, date of birth, the last four digits of your Social Security number, the email and physical addresses associated with your OSG account, one or more recent transactions, and the last four digits of the account. If you ask us to provide you with specific pieces of Personal Information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. We may decline a request where we are unable to authenticate you as the person to whom the data relates, the request is unreasonable or excessive, or where otherwise permitted by applicable law.
Except for the automated controls described in this notice, if you send us a request to exercise your rights or the choices in this section, to the extent permitted by applicable law, we may charge a fee or decline requests in certain cases. For example, we may decline requests where granting the request would be prohibited by law, could adversely affect the privacy or rights of another person, would reveal a trade secret or other confidential information, would interfere with a legal or business obligation that requires retention or use of the data, or because the data at issue is not covered under the law you are asserting.
Rights for Individuals Located in Connecticut
- You have a right to request that we disclose to you, once in a 12-month period, the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such Personal Information, which is also provided in this privacy statement.
- You also have rights to request that we correct inaccurate Personal Information under certain circumstances, subject to a number of exceptions.
- You have the right to request that we delete your Personal Information under certain circumstances, subject to a number of exceptions.
- You have the right to opt-out of targeted advertising and the sale of Personal Information. We do not “sell” data as it is defined under Connecticut law. However, OSG has combined various opt-outs into one (sale, share, and targeted advertising opt-outs).
- You have the right to appeal our decision to refuse to act on a Connecticut Data Privacy Act (“CTDPA “) data privacy request within a reasonable period after you receive our decision. To appeal our decision, forward your denial email to privacy@osgconnect.com for OSG’s privacy team to review your data subject request. Within 60 days, we will provide you with a written explanation of the reasons in support of our response. If you disagree with our explanation you have the right to contact or file a complaint with the Connecticut Attorney General.
- You have the right to not be discriminated against for exercising any of your privacy rights.
To help protect your privacy and maintain security, we will take steps to authenticate your identity before granting you access to your Personal Information or complying with your request (except for a request to opt-out of sales). We may require you to provide any of the following information: your name, date of birth, the last four digits of your Social Security number, the email and physical addresses associated with your OSG account, one or more recent transactions, and the last four digits of the account. If you ask us to provide you with specific pieces of Personal Information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. We may decline a request where we are unable to authenticate you as the person to whom the data relates, the request is unreasonable or excessive, or where otherwise permitted by applicable law.
Except for the automated controls described in this notice, if you send us a request to exercise your rights or the choices in this section, to the extent permitted by applicable law, we may charge a fee or decline requests in certain cases. For example, we may decline requests where granting the request would be prohibited by law, could adversely affect the privacy or rights of another person, would reveal a trade secret or other confidential information, would interfere with a legal or business obligation that requires retention or use of the data, or because the data at issue is not covered under the law you are asserting.
Rights For Individuals Located In North Dakota
If you are a North Dakota resident, you have rights regarding your Personal Information. Those rights and other state-specific information is described below:
Joint Marketing with other Financial Institutions. You have the right to opt-out of joint marketing with other financial institutions. You may opt out of joint marketing with other financial institutions by submitting a request through the OSG privacy link.
Rights For Individuals Located In Utah
- You have a right to request that we disclose to you, once in a 12-month period, the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such Personal Information, which is also provided in this privacy statement.
- To obtain a copy of your Personal Information that you previously provided to us in a portable format, please submit an “access” request as described above. While these requests are distinct, we have not identified any technically feasible and readily usable format that would allow you to transmit this data to another controller. Therefore, we will provide you a copy of your Personal Information so that we honor your request as best is technically feasible.
- You have a right to request that we delete your Personal Information under certain circumstances, subject to a number of exceptions.
- You have a right to opt-out of targeted advertising and the sale of Personal Information. We do not “sell” data as it is defined under Utah law. However, OSG has combined various opt-outs into one (sale, share, and targeted advertising opt-outs).
- You have the right to not be discriminated against for exercising any of your privacy rights.
To help protect your privacy and maintain security, we will take steps to authenticate your identity before granting you access to your Personal Information or complying with your request (except for a request to opt-out of sales). We may require you to provide any of the following information: your name, date of birth, the last four digits of your Social Security number, the email and physical addresses associated with your OSG account, one or more recent transactions, and the last four digits of the account. If you ask us to provide you with specific pieces of Personal Information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. We may decline a request where we are unable to authenticate you as the person to whom the data relates, the request is unreasonable or excessive, or where otherwise permitted by applicable law.
Except for the automated controls described in this notice, if you send us a request to exercise your rights or the choices in this section, to the extent permitted by applicable law, we may charge a fee or decline requests in certain cases. For example, we may decline requests where granting the request would be prohibited by law, could adversely affect the privacy or rights of another person, would reveal a trade secret or other confidential information, would interfere with a legal or business obligation that requires retention or use of the data, or because the data at issue is not covered under the law you are asserting.
To access the categories of third parties with whom Personal Information was shared during the 12-month period prior to the effective date of this Policy, please consult the table under “California Consumers” as our data sharing is the same regardless of the state of our members.
Rights For Individuals Located In Vermont
Rights For Individuals Located In Virginia
- You have a right to request that we disclose to you, twice in a 12-month period, the Personal Information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such Personal Information, which is also provided in this Policy.
- You have the right to request that we correct inaccurate Personal Information under certain circumstances, subject to a number of exceptions.
- You have the right to request that we delete your Personal Information under certain circumstances, subject to a number of exceptions.
- You have the right to opt-out of targeted advertising and the sale of Personal Information. We do not “sell” data as it is defined in under Virginia law. However, OSG has combined various opt-outs into one (sale, share, and targeted advertising opt-outs).
- You have the right to obtain a portable copy of your Personal Information. To obtain a copy of your Personal Information that you previously provided to us in a portable format, please submit an “access” request as described above. While these requests are distinct, we have not identified any technically feasible and readily usable format that would allow you to transmit this data to another controller. Therefore, we will provide you a copy of your Personal Information so that we honor your request as best is technically feasible.
- You have the right to appeal our decision to refuse to act on data privacy request within a reasonable period after you receive our decision. To appeal our decision, forward your denial email to privacy@osgconnect.com for OSG’s privacy team to review your data subject request. Within 60 days, we will provide you with a written explanation of the justification for declining to act on your request. If you disagree with our explanation you have the right to file a complaint with the Virginia Attorney General.
- You have the right to not be discriminated against for exercising any of your privacy rights.
To help protect your privacy and maintain security, we will take steps to authenticate your identity before granting you access to your Personal Information or complying with your request (except for a request to opt-out of sales). We may require you to provide any of the following information: your name, date of birth, the last four digits of your Social Security number, the email and physical addresses associated with your OSG account, one or more recent transactions, and the last four digits of the account. If you ask us to provide you with specific pieces of Personal Information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. We may decline a request where we are unable to authenticate you as the person to whom the data relates, the request is unreasonable or excessive, or where otherwise permitted by applicable law.
Except for the automated controls described in this notice, if you send us a request to exercise your rights or the choices in this section, to the extent permitted by applicable law, we may charge a fee or decline requests in certain cases. For example, we may decline requests where granting the request would be prohibited by law, could adversely affect the privacy or rights of another person, would reveal a trade secret or other confidential information, would interfere with a legal or business obligation that requires retention or use of the data, or because the data at issue is not covered under the law you are asserting.
Rights For Individuals Located In The European Union
Under the GDPR, individuals in the European Union are provided with certain rights regarding their Personal Data, as defined under that Regulation. The following section provides notice of these rights:
- You have the right to access your Personal Data. You have a right to know if we process any Personal Data about you and, be sent a copy of the Personal Data, along with an explanation of the purposes of the processing, and the categories of recipients to whom we have disclosed your Personal Data.
- You have the right of rectification of your Personal Data. You have the right to correct your Personal Data is it is inaccurate. You may change or update your information at any time by requesting access to the Personal Data that has been collected about you and confirm or change that information.
- You have the right to have your Personal Data erased under certain circumstances. You may exercise this right (a) if you withdraw your consent and there is no other lawful basis for processing the data; (b) if the data is no longer necessary for the purpose for which it was collected; (c) where you have objected to the use of the data for direct marketing; (d) where the data has been unlawfully processed; or (e) where erasure is necessary to comply with a legal obligation. Please note that there are also exceptions to this right that may prevent you from exercising this right. For example, if the data is necessary for the establishment, exercise, or defense of legal claims, your right to erasure will not apply.
- You have the right to restrict the processing of your Personal Data under certain circumstances. You may exercise this right if (a) you contest the accuracy of the Personal Data collected and retained about you; (b) if the processing is unlawful; (c) if the data is no longer necessary for the purposes of processing but it is required for the establishment, exercise, or defense of legal claims; or (d) if you have objected to the processing of your data based on the public interest or the legitimate interest of others.
- You have the right to object to the processing of your Personal Data. You have the right to object to direct marketing at any time. You can also object to the processing of your Personal Data which is based on legitimate interests. Likewise, you can object to the processing of your Personal Data for scientific or historical research or statistics purposes. Note that while the right to object to direct marketing is absolute, the two other rights to object are more limited.
- You have the right to port (transfer) Personal Data you have provided to us, either to you or to another provider. You may request to be given a copy the Personal Data that you have provided to us and that we have processed through automated means based on your consent in a commonly used, machine-readable electronic format where technologically possible, for your re-use.
- You have a right to revoke your consent to or to opt-out of how your Personal Data is processed as described in this Policy. You may withdraw consent to the extent that our processing of your Personal Data is based on your consent
- You have the right to lodge a complaint. If you have any concerns or a complaint about how your Personal Data has been or is being processed, please let us know directly by contacting us by email. You also have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated.
To find out more about your data subject rights under GDPR, you may contact the data protection agency of your member country, for e.g., the Data Protection Commission of Ireland.
To exercise your rights, please contact us: our contact details are in the “Contact Us” section below. Please make it clear which right(s) you want to exercise, for example by heading your letter “right to object” if you wish to exercise the right to object.
Notice Regarding Public Posting Areas
Please note that any information you include in a message you post to any public posting area is available to anyone with Internet access. If you do not want people to know your email address, for example, do not include it in any message you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN PUBLIC POSTING AREAS. OSG IS NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN PUBLIC POSTING AREAS.
Security Of Your Personal Information
We use appropriate technical and organizational measures to protect the Personal Information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Information.
International Data Transfers
OSG is based in the U.S. If you choose to provide us with information, please understand that your Personal Information may be transferred to the U.S. and that we may transfer that information to our affiliates, subsidiaries, partners or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from the EU or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your Personal Information to the U.S. and other jurisdictions which may not have the same levels of data protection as the EU, and Personal Information may be subject to access by and disclosure to law enforcement agencies in the U.S.
We put in place appropriate operational, procedural, and technical measures to ensure the protection of your Personal Information. You acknowledge and understand that by providing your Personal Information: (i) your Personal Information will be used for the uses identified above in accordance with this Policy; and (ii) your Personal Information may be transferred to the U.S. and other jurisdictions as indicated above, in accordance with applicable law.
Business Transfer
If all or part of our assets are sold or acquired by another party, or in the event of a merger, we retain the right to transfer your Personal Information to the successor business. The new business would retain the right to use your Personal Information according to the terms of this Policy as well as to any changes to this Policy as instituted by the new business.
How We Respond to Do-Not-Track Signals
Data Retention
How long we retain your Personal Information depends on the context in which, and purposes for which, we collected it. We generally retain Personal Information for as long as necessary for achieving the purposes for which it was collected or processed, unless a different retention period is required by applicable law, including the retention periods required under the GDPR and CCPA.
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
Changes to this Privacy Policy
We reserve the right to change this Policy without prior notice to reflect changes in our Personal Information practices or applicable law. We encourage you to periodically review this Policy to keep up to date on how we are handling your Personal Information.
Contact Us
If you have any questions, comments or concerns about our privacy practices or this Policy, please contact us at:
OSG
osgconnect.com / privacy@osgconnect.com
900 Kimberly Drive
Carol Stream, IL 60188
630-597-9100
