Privacy Policy

Last Updated: June 28, 2024Effective Date: June 28, 2024IntroductionThis Privacy Policy covers how Osano, Inc. A Public Benefit Corporation ("Osano", "we", "our") collects, uses, discloses and stores information about you ("personal information") when you use our website or platform, or when you attend in-person events, such as live demonstrations. Learn more about Osano software. This Privacy Policy also addresses any information collected from any acquired or assigned rights from Wirewheel, Inc. (Wirewheel).

For the purposes of this Privacy Policy, Osano is a Processor (provides services to its customers) when it gathers data from its customers to provide Osano’s services. Osano is a controller (i.e. the responsible party determining how data is to be used) for data gathered for its own purposes, including website visitors and marketing.

For more information about the privacy practices of an Osano business customer or a customer affiliate, please contact the respective business customer directly. We are not responsible for the privacy or data security practices of our business customers, which may differ from those set forth in this Privacy Policy.

For more detailed information, please click the links below to visit sections of our Privacy Policy:IntroductionWhat Information We Collect and How We Collect ItHow We Use the Information We CollectLegal Basis for Collecting and Using InformationWith Whom We Disclose InformationCookiesSecurityData RetentionData Transfers and EU-US & Swiss-US Data Privacy FrameworkChildren's Privacy"Do Not Track" and Global Privacy ControlLinks to Other WebsitesYour RightsChanges to this Privacy PolicyHow to Contact UsWhat Information We Collect and How We Collect ItTo provide our services to you and to ensure that our software and platform operate correctly, we collect various types of information, including personal information. When you use our website, sign up for our services, and use our software or platform, we collect the following categories of information:Information you provide to us:Identifiers and Contact Information. If you use the contact information provided on the Osano.com website to contact us directly, you agree to allow Osano to store and process your contact information. We will receive your contact information which could include, depending on how you contact us, your email address, name, company name, job title, the reason for contacting, and postal address.Customer Contact and Account Information. We receive and store the information you provide directly to us when you sign up for and use our services and platform. The types of information we may collect directly from our customers and users include name, email address, mailing address, phone number, job title, payment and billing information, and any other information provided by the user (including a user-submitted photograph if a user chooses to provide one with respect to our data subject access request feature).When you use our website or platform, we automatically collect the following information:Internet Protocol Address (“IP address”). IP addresses are assigned by your Internet service provider (e.g., Comcast/Xfinity, AT&T, Time Warner, Verizon, Charter, etc.) to the modem used to access the Internet for connected devices in your home and/or work-place. Any devices using the modem to access the Internet may broadcast the same IP address. At home, connected devices could include one or more laptop/desktop computers, tablets, mobile phones, smart/connected TVs and gaming consoles. At work, connected devices could include one (or all) floor(s) in an office building. Our website receives your IP address from your Internet browser each time you request a file or web page.User-Agent. Due to the nature of how the Internet works, we may receive information (known as “User-Agent”) automatically sent by your web browser, such as data associated with the source device’s Internet browser/content delivery software (e.g., Microsoft Explorer, Mozilla Firefox or Google Chrome). The User-Agent information we receive may also include information such as device type (e.g., computer, tablet, mobile device), and/or date/time of visit. Similar to the collection of IP addresses, our website also receives User-Agent information associated with your browser and type of device.Information collected by cookies and other similar technologies. We use various technologies to collect information which may include saving cookies to users’ computers. These tools help us understand and improve the performance of the Osano website and platform.  Our cookie policy can be found here.We do not collect sensitive personal information other than as may be necessary to collect payment from our customers for our products and services. Unless we specifically request such sensitive information from you, we ask that you not send it to us or disclose any sensitive personal information to us.Finally, we may also receive personal information about you from third parties, such as social networks, that help us identify prospective businesses or customers that might be interested in our products and services.How We Use the Information We CollectWe use personal information for the following business purposes associated with our general business operations. We may collect your personal information for the following processing purposes:Services. We may use the personal information we collect in connection with the services we provide.  We may use the personal information we collect to set up user accounts; provide, operate, and maintain services; process and complete transactions; provide customer service and support and respond to inquiries; send communications; prevent fraudulent activity; for any other purpose based on our legitimate interest.Website. We may use the personal information we collect to administer and improve the Osano website and platform.Promotional Communications. We may use your personal information to contact you with newsletters, marketing or promotional materials, and other information that may interest you. You may opt out of receiving any, or all, of these communications from us by following the instructions provided in any email we send or by following the unsubscribe link in those emails.Marketing.  We may use the personal information we obtain from you, your interactions with us and our website, as well as from third parties who help us with our marketing efforts, to provide you with marketing and promotional content, to deliver targeted and relevant advertising and marketing to you, to determine the effectiveness of our marketing, prospecting and sales campaigns and to better understand our website visitors’ preferences.  You can view and change your preferences concerning this use of information through your cookie settings or by submitting a data subject request to us.Analytics. We may use analytics information collected to understand general information and trends related to our website, such as how many users have visited our website during a given period of time and the types of devices the visitors use. The information is used by us to help improve consumers' solutions.IP addresses – Fraud Prevention. Our use of IP addresses is limited to helping identify and combat potentially fraudulent activity. IP addresses are stored in our log files and are deleted after 30 days.Respond to Inquiries. If you choose to contact us directly (by email, form, or postal mail) using the contact information we provide on the Osano website, we will use your contact information to respond to your inquiry.Legal Basis for Collecting and Using InformationIf you are a user of the Osano website or platform located in the EEA, we rely on several processing purposes, such as legitimate interest, as the legal basis for processing the personal data we collect via the website and platform. For instance, we may collect, process or disclose your personal information based on the following bases:As necessary to provide a service or perform a transaction (such as when we respond to your requests);Consent (where you have provided consent as appropriate under applicable law, such as for direct marketing or certain cookies);As necessary for legitimate interests (such as when we act to maintain our global business generally, including maintaining the safety and security of the Site); andCompliance with legal obligations, particularly in the area of labor and employment law, social security and protection law, data protection law, tax law, and corporate compliance laws.The provision of your personal data is partly a statutory requirement and partly a contractual obligation.With Whom We Disclose InformationWe may disclose information (including personal information) in the following instances:Vendors and Service Providers. We may disclose your information to vendors and service providers we engage to perform tasks on our behalf, for example, to help us deliver our services, bill our customers, and respond to support tickets. More details about these vendors and service providers can be found in our GDPR statement.Marketing. We may disclose your information to service providers and advertising networks as reasonably necessary for marketing our products and services.Affiliated Companies. We may disclose personal information with subsidiaries, affiliates or strategic partners as needed to provide our products and services and generally as necessary in the administration of a global organization.Corporate activity. If Osano is acquired or merged with another company, we will transfer the collected information to the acquiring company.Applicable order. Under certain circumstances, we may be required to disclose personal information if necessary to comply with a subpoena or court order, to establish or exercise our legal rights or defend against legal claims, or to cooperate with government and/or law enforcement officials.Other Disclosures With Your Consent. We may disclose your personal information with your consent to other unaffiliated third parties who are not described elsewhere in this Privacy Policy.We may disclose de-identified information (i.e., information that cannot be used to identify an individual) for a variety of reasons, including under the following circumstances:To make our products better and foster transparency.If Osano is acquired or merged with another company, we will transfer aggregate information to the acquiring company.We may share de-identified information if necessary to comply with a subpoena or court order, to establish or exercise our legal rights or defend against legal claims, or to cooperate with government and/or law enforcement officials.For any lawful basis.CookiesThe Osano website and platform may place cookies on your browser in order to identify you when you return to our website or log in to our software. You can also manage your privacy preferences with us anytime by clicking the cookie icon on our website. Osano’s cookie policy can be found here.SecurityWe take security very seriously. Osano has implemented reasonable technical, administrative and organizational security controls designed to protect the confidentiality, integrity, availability and resilience of data. These measures include utilization of encryption technologies, creation and maintenance of policy overseeing the management of the security program, role-based access controls, password management, vulnerability management and secure software development protocols.Data RetentionThe time period for which we retain your personal information depends on the purpose for which we use your personal information and the applicable law for that type of personal information and use. Osano will keep your personal information for as long as you are using our services and platform or as long as we have a valid business purpose to do so and, thereafter, for no longer than is required or permitted by law.

Generally, if you provide information to us to request a demo, we will keep that information for up to twelve months after your last communication with us. Other information collected during your use of our website will be kept until you withdraw consent or your information is no longer needed for marketing or analytical purposes.

We will generally keep personal information collected by our platform or provided by customers for up to three months after the end of our business relationship and subject to our agreement with our customers.  All payment information will be deleted three months after the processing unless we are required by law to keep it longer.

If you contact us directly using the contact information provided on the Osano website, we will generally retain your contact information for up to three months after we respond to your inquiry. After that, the communications will be deleted from our system unless we are required by law to retain them longer.Data Transfers and EU-US & Swiss-US Data Privacy FrameworkFor visitor-facing components of Osano, such as the Osano Consent Management platform, all personal data are stored exclusively in Dublin, Ireland. Nevertheless, certain personal information may be stored or accessible outside of the European Economic Area, Switzerland, or the United Kingdom. For such transfers of personal information and/or where required by law, Osano relies on the Standard Contractual Clauses as a valid transfer mechanism.

Osano complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Osano has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF.  Osano has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. Osano adheres to the DPF principles for onward transfers of personal data to third parties and remains liable for damages caused by third parties under the DPF. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

EU and Swiss individuals with inquiries or complaints regarding our Data Privacy Framework policy should first contact Osano at:
Osano, Inc., a Public Benefit Corporation
Attn: Legal
3800 N Lamar Blvd
Ste 200
Austin, TX 78756

Osano has further committed to refer unresolved Data Privacy Framework complaints to JAMS, an alternative dispute resolution provider in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

If JAMS doesn’t address your concern, you may be entitled to binding arbitration under the Data Privacy Framework Principles. For purposes of enforcing compliance with the Data Privacy Framework, Osano is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission.Children's PrivacyThe Osano website and platform were not developed or intended for individuals under the age of 18 and we do not knowingly collect information from children under the age of 18 years old. If you provide your information to us through a request form or any part of our platform you represent to us that you are at least 18 years old. If you learn that your child has provided us with personal information without your consent, you may alert us at legal@osano.com, and we will promptly take steps to delete such information."Do Not Track" and Global Privacy ControlDo Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals.Global Privacy Control is a browser setting that allows you to notify websites you visit about your privacy preferences. We honor website visitors’ Global Privacy Control signals.Links to Other WebsitesOsano’s website may contain links to other websites for your convenience and information.  These websites may be operated by companies not affiliated with Osano.  Linked websites may have their own privacy policies or notices, which we recommend you review if you visit those websites.  This Privacy Policy only applies to personal information collected on this website.  We have no control over third-party websites and are not responsible or liable for the content, privacy practices, or use of any websites that are not affiliated with Osano.Your RightsYou may be able to exercise certain privacy rights. The rights available to you depend on our reason for processing your personal information and the requirements of applicable law (i.e., your rights will vary depending on whether you are located In, for example, the European Union, the United Kingdom, Brazil, or California). Specifically, you may have the following rights:The right to confirmation on the existence of processing and to access the data: You may have the right to obtain from us confirmation as to whether personal information processed, and, where that is the case, to request access to the personal information. Depending on where you are located, you may also have the right to information about public and private entities with which the controller has disclosed personal data.The right to correct incomplete, inaccurate, or out-of-date data: You may have the right to request that we correct any personal information about you that is inaccurate.  Depending on the purpose of the processing, you also have the right to request that we complete the personal information we hold about you where you believe it is incomplete, including by means of providing a supplementary statement.The right to the portability of data: You may have the right to request that we transfer the personal information we have collected about you to another organization, or directly to you, in a structured, commonly used, and machine-readable format, under certain conditions.The right to request anonymization, blocking, or deletion of personal information: You have the right to request the deletion of your personal information we have collected from you, subject to certain conditions and limitations under the law.The right to revoke consent: Where we rely on your consent to process your personal information, you have the right to withdraw that consent at any time with future effect. Depending on where you are located, you may also have the right to request deletion of personal data that was processed based on your consent, or the right to know the consequences of revoking your consent. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.The right to object to processing: You may have the right to object to our processing of your personal information, under certain conditions, and we can be required to no longer process your personal information.  Such right to object may especially apply if we collect and process your personal information through automated decision making, such as profiling, to better understand your interests in our products and services or for direct marketing.  If you have a right to object and you exercise this right, your personal information will no longer be processed by us for such purposes.  Such a right to object may, in particular, not exist if the processing of your personal information is necessary to take steps prior to entering into a contract or to perform a contract already concluded.The right to opt-out of the sale or sharing of personal information: We do not sell your personal information in exchange for monetary consideration. In the event that we disclose your personal information to third parties for their marketing purposes, you may have the right to opt out of that disclosure. You may also have the right to request further information about the disclosure of your personal information for those third parties' marketing purposes, such as the contact information of those parties, once per calendar year.The right to limit the use and disclosure of sensitive personal information: We will only use sensitive or special personal information as needed for the purposes for which it was collected or with your consent. We do not currently process sensitive personal information for purposes that may be limited under applicable law. If this changes, we will notify you, and you may have the right to restrict such additional uses.The right to non-discrimination for exercising a privacy right: We will not discriminate against you for exercising any rights.The right to obtain a list of third parties to which personal information was disclosed. You can find a list of the subprocessors who may process data in order to provide Osano offerings here.Exercising rightsTo exercise any of your rights as set out above, please contact us by submitting a request at https://www.osano.com/legal/dsar or by contacting us at Osano, Inc., 3800 North Lamar Blvd, Suite 200, Austin, TX 78756. Please note that you will need to verify your identity before we can fulfill your request. Your request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of that person; and (ii) describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We will respond to your verifiable request within any prescribed timelines. In some regions, there may be limitations on how often a request relating to personal information may be submitted. If you are a Wirewheel customer, please submit your request to DSAR Wirewheel Form.Appointing an authorized agentYou can designate an authorized agent to submit a request on your behalf. To do so, you will need to provide a written authorization or power of attorney signed by you for the agent to act on your behalf. You will still need to verify your identity with us.AppealsIn some locations, you may be able to appeal any decision relating to a request to personal information. You can reach out to legal@osano.com if you have any questions.Unsubscribe from marketingYou can opt out of receiving certain marketing or promotional communications from Osano at any time by using the unsubscribe link in the email communications we send.Changes to this Privacy PolicyWe may update this Privacy Policy from time to time based on changes to applicable laws and regulations or other requirements applicable to us, changes in technology, or changes to our business.Any changes we make to the Privacy Policy in the future will be posted on this page, so you should review it periodically.If there are significant changes to our information practices, specifically how we process personal information, you will be provided with appropriate online notice. We will also post a notice on our home page if our Privacy Policy has changed.How to Contact UsIf you have any questions about this Privacy Policy or its implementation, you may contact through Osano's privacy webform, available at https://www.osano.com/legal/dsar us here or you can send correspondence to the following address:USA HeadquartersOsano, Inc., a Public Benefit Corporation3800 North Lamar BlvdSuite 200Austin, TX 78756European HeadquartersOsano International ComplianceServices Limited25/28 North Wall QuayDublin 1 D01 H104IRELANDUK HeadquartersOsano UK Compliance Ltd42-46 Fountain StreetBelfastAntrimBT1 5EFIf contacting us does not provide you with an adequate resolution and your inquiry is related to information collected about you in the European Union/European Economic Area, please contact the applicable EU Data Protection Authority.