PRIVACY POLICY

Last modified: March 28, 2024

ONOtag Inc., a Delaware corporation (“Company,” or “ONOtag”), respects your privacy and is committed to protecting it through our compliance with this privacy policy (“Privacy Policy”) as may be referred to in other Company documentation, including but not limited to the Terms of Use.

This Privacy Policy aims to explain the type of information we may collect and to inform you of the specific practices and guidelines that protect the security and confidentiality of personal information. This Privacy Policy governs your usage of the ONOtag mobile application (the “App”) to access our Services (as defined in the Terms of Use). By using the App, you also agree to the Google Privacy Policy.

This Privacy Policy applies to information we collect on the App:

• when you are using the App, or
• when you submit a form to create an Account (as defined in the Terms of Use), or
• in text messages, phone calls, emails and other electronic messages between you and the Company.

It does not apply to information:

• collected by the Company offline or through any other means, including on any other website operated by the Company or any third party; or
• any third party, including through any application or content that may link to or be accessible from or on the App.

By using the App, you accept and agree to be bound and abide by the Privacy Policy. Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will handle it. If you do not agree with our policies and practices, your remedy is to not access and use the App. This Privacy Policy may change from time to time. We will use our best effort to provide email notices to any registered users about the changes to our Privacy Policy. Your continued use of the App after we make changes to our Privacy Policy is deemed to be the acceptance of those changes, so please check this Privacy Policy periodically for updates.

1. Age Restriction

Our App is designed for users over the age of 13. In adherence to our commitment to protect the privacy of young children, we do not knowingly collect personal information from individuals under the age of 13. If we discover the inadvertent collection of personal information from a user under this age threshold, we will promptly take steps to delete such information. Should you have concerns that your child, under the age of 13, may have provided us with personal information, we encourage you to reach out to us immediately. Requests for the deletion of this information can be made by contacting us via email at support@onotag.com.

2. The Information We Collect

We collect several types of information from and about users of the App, including the following:

• Personal Information: When you access the App, we may ask you to voluntarily provide us with certain information that personally identifies or could be used to personally identify you (“Personal Information”). Personal Information includes, but is not limited to, contact information (such as your name and e-mail address). We may also collect additional information, which may be Personal Information, as otherwise described to you at the point of collection or under your consent.
• Public Content: The Content you choose to post on or upload to the App will be viewable by other users who are your “friends” on the app, including your photos, tags and takes. Your account profile (e.g., display name and profile photo) may also be shared with other users of the App.
• Chat Transcripts: While we generally do not monitor transcripts of chats between users, we may occasionally review the chat transcripts to conduct quality control, address potential safety issues, and prevent misuse of our platform, if a certain suspicious or potentially harmful activity is detected. We may also use aggregated data from chat transcripts to conduct research and development.
• Traffic Data: When using the App, we also may automatically collect data including your IP address, domain server, type of mobile device(s) used to access the App, any referring webpage or other source through which you accessed the App, geolocation information and other statistics and information associated with the interaction between your device and ONOtag (collectively called “Traffic Data”). The App may also collect and store data regarding your location whenever our mobile applications are running, including when running in the background, if you enable our mobile apps to access such information while using the Service. You may be able to limit or disallow our use of certain data through your device settings, for example you may be able to limit or disallow our collection, use or sharing of location data or mobile advertising identifiers by adjusting the settings for our applications in iOS or Android privacy settings. The App uses the Google Places API(s).

3. How We Collect Information

We collect the above-mentioned types of information from you when you provide it to us when you register for an account to use the App and as part of providing some of our Services to you.

As you navigate through and interact with the App, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including details of your usage (including traffic data, geolocation data, logs, and other communication data), information about your phone and internet connection (including your IP address, operating system, and browser type) and behavioral tracking (including online activities over time and across third-party websites or other online services. We may also collect information that your mobile device provides to us in connection with your use of the Services.

We may also ask you for information when you report a problem with ONOtag and retain records and copies of your correspondence (including email addresses), when you contact us. Details of any transactions you carry out through ONOtag may also be collected when you provide financial information when placing an order. We may also collect information you authorize third parties to release to us, such as from our business partners.

The technologies we use for this automatic data collection may include:

• Strictly Necessary Cookies. These cookies are essential because they enable you to move around and use our Services. For example, strictly necessary cookies allow you to access secure areas on our Services. Without these cookies, some services cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Services to function and they cannot be disabled.
• Functional Cookies. We use functional cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Services. While these cookies can be disabled, this may result in less functionality during your use of our Services.
• Performance or Analytic Cookies. These cookies collect anonymous passive information about how you use our Services, including webpages you visit, and links you click. We use the information collected by such cookies to improve and optimize our Services.
• Third-Party Cookies. These are cookies that are provided by third-party service providers and belong in one of the cookie categories described above. These third-party providers process your Personal Information on our behalf pursuant to our instructions and obligations consistent with this Privacy Policy.

4. How We Use Your Information

ONOtag may use the information the App collects about you or that you provide to us, including any Personal Information:

• to present the App and its contents to you,
• to provide you with information or Services that you request from us,
• to provide customer support and respond to your inquiries,
• to enhance the App and optimize your experience with the App,
• to recognize you and provide you with customized Services,
• to carry out our obligations and enforce our rights arising from any contracts entered between you and ONOtag,
• to notify you about changes to the App, your account and subscription, including expiration and renewal notices,
• to ensure the App’s network and information security,
• in any other way we may describe when you provide the information to us,
• for any other purposes with your consent.

5. How We Share Your Information

ONOtag will not sell your Personal Information that the App collects or that you provide to us to any third party.

ONOtag may share and disclose your Personal Information as follows:

• Third Party Service Providers Performing Services on Our Behalf. We may share your Personal Information with certain third-party service providers that assist us in providing the Services and which are bound by duties of confidentiality. For example, we may use third parties to host the Services, to send out email updates about the Services, administrative services, quality assurance, data aggregation or remove repetitive information from our user lists.
• For Legal Purposes. We will disclose your Personal Information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share your Personal Information as required to pursue available remedies or limit damages we may sustain.
• Welfare Assurance. We may disclose your Personal Information directly to law enforcement or local authorities if it has been reasonably determined that your safety or the safety of others may be at risk.
• Business Transfer. In the event of a merger, reorganization, consolidation, restructuring, bankruptcy, sale of substantially all interests or assets, or other similar transaction, we may transfer your Personal Information to the subsequent owner or operator of the Services.
• Anonymized Data. We may de-identify your Personal Information, in compliance with applicable law and aggregate such de-identified data with the de-identified data of other users. ONOtag uses such de-identified data for research and development purposes. For example, analytics and error reports are sent to Google (Firebase); geo queries are sent to Google (Places API), and tag search queries are sent to Google (Tenor).

6. Choices About How We Use and Disclose Your Information

ONOtag strives to provide you with choices regarding the information you provide to us. The privacy settings in the App are available for you to adjust how we use and disclose your information.

You can choose whether or not to allow the App to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the App may become inaccessible or not function properly.

If you do not want us to use your email address to send you information regarding our own products or services, you can choose to opt-out by logging into the App and adjusting your user preferences in your account profile, or simply unsubscribe from the email list through one of the emails you received from us.

If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can choose to opt-out of targeted advertising. You can also always adjust your user advertising preferences in your account profile by checking or unchecking the relevant boxes.

7. Data Security

We use a combination of technical, administrative, and physical controls to maintain the security of your data. If you have a security-related concern, please contact us immediately. Always be sure to secure your login credentials for accessing the App. To protect you and your information, we may suspend your use of any of the Service, without notice, pending an investigation, if we suspect any breach of security.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of the Personal Information you transmit to ONOtag. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the App.

We have implemented measures designed to reasonably secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.

8. Links to Third Party Websites

The App may contain links to third party websites and services and some of those third-party websites may be co-branded with our logo (“Third-Party Services”). These Third-Party Services are not our Services. We do not control (and are not responsible for) third party content or privacy practices. Any personal information you provide to them is not covered by this Privacy Policy. We encourage you to review carefully the legal and privacy policies of all other digital services that you visit.

9. Changes to Your Information

All users may review, update, correct or delete the Personal Information or the profile picture in their user account by logging into the App and modify the user profile or by contacting us at support@onotag.com. If you completely delete all of your information with us, then your user account will be deactivated.

10. Data Retention and Account Termination

You may close your Account in “Settings” in the App or by emailing us at support@onotag.com. We may terminate your account after one year of inactivity. After the termination of your account, we may retain information about you for the purposes authorized under this Privacy Policy unless prohibited by law. For example, we may retain information to prevent, investigate, or identify possible wrongdoing in connection with the Services or to comply with legal obligations. We may also maintain residual copies of your Personal Information in our backup systems.

11. Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the App’s home page. If we make material changes to how we treat our users’ Personal Information, we will notify you by email to the email address specified in your account or through a notice on the App’s home page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you to receive such notices.

12. Contact Information

If you have any questions, concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any suspected security violations to us, please contact us at support@onotag.com.