Privacy Policy

Effective Date : January 25, 2024

This Privacy Policy describes how ONNA Media Inc. (“ONNA,” "we," "our," or "us") collects, uses, and shares information about you and applies to your use of any online service location that posts a link to this Privacy Policy, including our website located at www.onnamedia.com, and all features, content, and other services that we own, control, and make available through such online service location (collectively, the "Service"). By using the Service, you agree to our collection, use, and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree with this Privacy Policy, then do not use the Service.

This Privacy Policy does not apply to information collection activities outside of the Service, such as ONNA Media's products and services that ONNA Media's clients may use to collect information on their own behalf (unless otherwise stated below or at the time of collection). For information about processing on behalf of our clients, please see the section entitled "Client Data" below.

If you have any questions or wish to exercise your rights and choices, please contact us as set out in the "Contact Us" section. If you are in Europe or a California resident, please see our location-specific disclosures in the "Additional Disclosures for People in Europe" and Additional Disclosures for California Residents" sections below.

Information Collection

Information You Provide to ONNA Media

ONNA Media collects information that you voluntarily submit to ONNA Media through the Service. The categories of information we collect and have collected in the last 12 months include:

Contact Data , including your or your employer's name, email address, phone number, and physical address; and
Job Applicant Data , including your employment and education history, such as transcript, writing samples, and references as necessary to consider your job application for open positions.

Do not submit any information to us that we have not requested.

Information Collected Automatically

ONNA Media also automatically collects certain information about your device and how your device interacts with our Service. The categories of information we automatically collect and have collected in the last 12 months include your device's IP address and other device identifiers, the type of internet browser you are using on your device, the type of operating system application software and peripherals you are using on your device, the domain name of the website from which your device linked to our Service, and your browsing habits on and usage of the Service through your device.

We use various current – and later – developed technologies to collect this information ("Tracking Technologies"), including the following:

Cookies A cookie is a small data file that certain websites write to your hard drive when you visit them. We may also use web bugs, clear gifs and similar technologies that collect data similar to that collected by a cookie. A cookie file can contain various types of information, including a user ID that the site uses to track the pages you have visited.
Pixels. A pixel (also known as a web beacon) is code embedded in a website, video, e-mail, or advertisements that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, e-mail, or advertisements that contains a pixel, the pixel may permit us or another party to drop or read cookies on your device. Pixels are used in combination with cookies to track activity by a particular browser on a particular device.
Location-identifying Technologies. Location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting relevant content based on your location.

For further information on Tracking Technologies and your rights and choices regarding them, please see the sections entitled "Analytics and Advertising" and "Your Rights and Choices" below.

Information on Behalf of Our Clients.

We provide marketing and advertising products and services for our clients, and may collect and process information about individuals at the direction of our clients ("Client Data"). Client Data has historically included contact data, demographic data, social handles, content, internet activity, and location data, among other information. Our processing of Client Data is governed by the terms of our service agreements with our client, and not this Privacy Policy. We are not responsible for how our client treat the information we collect on their behalf, and we recommend you review their own privacy policies.

ONNA Media acknowledges that you may have rights in connection with Client Data. If your information has been processed by ONNA Media on behalf of a client and you wish to exercise any rights you have with such information, please inquire with our client directly. If you wish to make your request directly to ONNA Media, please provide the name of the ONNA Media client on whose behalf ONNA Media processed your information. We will refer your request to that client, and will support them to the extent required by applicable law in responding to your request.

Information from Other Sources.

We may obtain information about you from other sources.The categories of other sources from which we collect and have collected information from in the last 12 months include:

Social networks when you reference our Service or grant permission to us to access your data on one or more of these services;
Data providers, such as Cuebiq. Cuebiq’s privacy policy is available at https://www.cuebiq.com/privacypolicy/;
Partners with which we offer co-branded services or engage in joint marketing activities; and
Publicly-available sources such as data in the public domain.

Use of Information

ONNA Media uses information we collect for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information, including in the last 12 months, include:

To operate and manage our Service;
To perform services requested by you, such as to respond to your comments, questions, and requests, and provide customer service;
To send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
To prevent and address fraud, breach of policies or terms, and threats or harm;
To monitor and analyze trends, usage, and activities; and
To improve the Service or other ONNA Media websites, applications, marketing efforts, products and services.
To send you direct marketing about our products, services, offers, promotions, rewards, and events we think you may be interested in;
To provide you with advertisements; and
To fulfill any other business or commercial purposes disclosed to you and with your consent.

We may use information that does not identify you (including information that has been de-identified) without obligation to you except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the section entitled "Your Rights and Choices" below.

Sharing of Information

ONNA Media shares information we collect through the Service in accordance with the practices described in this Privacy Policy. The types of entities to whom we disclose and have disclosed information with in the last 12 months, are as follows:

Service Providers. Our agents, consultants, and other service providers (collectively "Service Providers") may process your information in connection with their work on our behalf. These Service Providers are contractually prohibited from retaining, using, or disclosing your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other commercial purposes.
Affiliates. We may share your information with our affiliates for internal business purposes. For example, we may share your information with our affiliates for customer support, marketing, or technical operations.
Vendors and Other Parties. We may share information with vendors and other parties for business and commercial purposes, including analytics and advertising technology companies. Vendors may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising, see the "Analytics and Interest-based Advertising" section below.
Sweepstakes, Contests, Promotions.We may offer sweepstakes, contests, surveys, and other promotions (each, a "Promotion") jointly sponsored or offered by other parties. If you voluntarily choose to enter a Promotion, your information may be disclosed to other parties for administrative purposes and as required by law (e.g., on a winners list). By entering, you agree to the official rules that govern that Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.
Clients. We share information with our clients in connection with us processing information on their behalf. For example, we share information with our clients in order to address your requests, market and advertise to you, and otherwise comply with applicable law.
Merger or Acquisition. We may share your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
Security and Compelled Disclosure. We may share your information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share your information as required by courts or administrative agencies and to the extent necessary to permit us to investigate suspected fraud, harassment or other violations of any law, rule or regulation, the Service rules or policies, or the rights of other parties or to investigate any suspected conduct which ONNA Media deems improper. We may also share your information to protect the rights, property, life, health, security and safety of us, the Service or any other party.
Consent. We may share your information for any other purpose disclosed to you and with your consent.

Without limiting the foregoing, we may share aggregated information which does not identify you or de-identified information with other parties or affiliates except as prohibited by applicable law.For information on your rights and choices regarding how we share your information, please see the section entitled "Your Rights and Choices" below.

Social Media and Technology Integrations

Our Service contains content from and hyperlinks to websites, locations, platforms, and services operated, owned, and maintained by other parties. In addition, we integrate technologies operated or controlled by other parties into parts of our Service. For example, we hyperlink from our Services to websites, social media platforms, and other services not operated or controlled by us. These other parties may use Tracking Technologies to independently collect information about you and may solicit information from you. Also, if you use one of their features, both we and the applicable other party may have access to and use information associated with your use of that feature. If you publicly reference our Service on a social network (e.g., by using a hashtag associated with ONNA Media in a tweet or post), we may use your reference on or in connection with our Service.

The information collected and stored by other parties, whether through our Service, or another parties' service or device, remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. ONNA Media is not responsible for and makes no representations regarding the privacy practices of other parties. You should carefully read their own privacy policies before providing any information to such parties.

Analytics and Advertising

Our Service also contains Tracking Technologies, some which are operated by vendors or other parties. For example, analytics services, such as Google Analytics, may use Tracking Technologies on our Service to help us analyze your use of the Service, compile statistic reports on the Service's activity, and provide other services relating to Service activity and internet usage. Similarly, ad serving services, advertisers, and other parties may use Tracking Technologies on our Service and other services to track your activities across time and services, and tailor ads to you based on your activities, which may include sending you an ad on other websites or devices after you have left the Service ("Interest-based Advertising").

For further information on Tracking Technologies and your rights and choices regarding them, please see the sections entitled "Information Collected Automatically" above and "Your Rights and Choices" below.

Your Rights and Choices

Tracking Technologies Choices

Most browsers are initially set up to accept cookies; however, you generally can reset your browser to refuse all cookies or indicate when a cookie is being sent or you can flush your browser of cookies from time to time. (Note: you may need to consult the help area of your browser application for instructions.) If you choose to disable cookies or refuse to accept a cookie, you may not be able to utilize all features of the Service.

Your browser settings may allow you to automatically transmit a "Do Not Track" signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to "Do Not Track" signals or other mechanisms. For more information on "Do Not Track," visit http://www.allaboutdnt.com.

Analytics and Interest-Based Advertising

You may exercise choice regarding the use of cookies from Google Analytics by visiting https://tools.google.com/dlpage/gaoptoutor downloading the Google Analytics Opt-out Browser Add-on.

Some of the parties that collect information from or about you on the Service in order to provide more relevant advertising to you participate in the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising. This program offers a centralized location where users can make choices about the use of their information for online behavioral advertising. To learn more about the DAA and your opt-out options for their members, please visit http://www.aboutads.info/choices. In addition, some of these parties may be members of the Network Advertising Initiative ("NAI"). To learn more about the NAI and your opt-out options for their members, please visit http://www.networkadvertising.org/choices/. Please note that if you opt-out of online behavioral advertising using any of these methods, the opt-out will only apply to the specific browser or device from which you opt-out. To limit targeted advertising on iOS and Android, visit your device settings and: (i) reset your Advertising Identifier; and (ii) turn off “Ad Personalization” (Android) or turn on “Limit Ad Tracking” (iOS). Further, opting-out only means that the selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). We are not responsible for effectiveness of, or compliance with, any other parties' opt-out options or programs or the accuracy of their statements regarding their programs.

Communications

You have the option to opt-out of receiving promotional emails from ONNA Media by clicking on the unsubscribe link that appears at the bottom of every promotional email that is sent out to you by ONNA Media in relation to this Service, or contacting us at info@onnamedia.com with the word UNSUBSCRIBE in the subject field of the email. Please note that your opt-out is limited to the email address used and will not affect subsequent subscriptions.

Data Security

We take reasonable steps to help protect the security of your information. To help prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of information, we have put into place physical, electronic, and managerial procedures. However, due to the inherent open nature of the internet, we cannot guarantee the security of your information collected through the Service.

Children

The Service is not intended for users under the age of 13, and we do not knowingly collecting personal information as defined by the U.S. Children's Privacy Protection Act ("COPPA") in a manner that is not permitted by COPPA. If a parent or guardian learns that a child has provided us with personal information, that child's parent or guardian should email us at info@onnamedia.com or send us a letter to the mailing address in the section entitled "Contact Us" below. We do not knowingly "sell," as that term is defined under the CCPA, the personal information of minors under 16 years old who are California residents.

International Transfer

Our Service is maintained in the United States of America, and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored and used in the U.S. and other countries or jurisdictions around the world. Data protection laws in the U.S. and other countries may be different from those of your country of residence. By using the Service, you freely and specifically give us your consent to the transfer to and from, processing, usage, sharing, and storage of your information in the U.S. or any other jurisdictions where we conduct business or provide services.If your data is collected in the European Union, we will transfer your personal data subject to appropriate or suitable safeguards, such as standard contractual clauses.

Changes to this Privacy Policy

We may amend our Privacy Policy at any time and will post those changes on this page, so you can understand what information we collect, how we use it, and under what circumstances we may disclose it. Any changes will be effective immediately upon posting of the revised Privacy Policy. However, if we plan to materially change the way in which we use or disclose your information, we will provide you with prior notice and a chance to opt-out of such differing uses.

Contact Us

If you have any questions about this Privacy Policy, the practices of this Service, or your dealings with this Service, you can contact us at info@onnamedia.com.

For European-specific requests, you can contact us at info@onnamedia.com.

If you have a disability and would like to access this Privacy Policy in an alternative format, please contact us at info@onnamedia.com.

Additional Disclosures for US Residents

Residents of certain US states, such as California, Virginia, Colorado, Connecticut, and Utah, have specific rights regarding their Personal Data. This section describes how to exercise those rights and our process for handling those requests. (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.)

2.1 Right to request access to your Personal Data

You may request access to your Personal Data that we collect, use, disclose, or sell. In particular, you may request:

the specific pieces of Personal Data that we process about you
the categories of Personal Data we have collected about you;
the categories of sources from which the Personal Data was collected;
the categories of Personal Data about you we disclosed for a business purpose or sold or shared;
the categories of third parties to whom the Personal Data was disclosed for a business purpose or sold or shared; and
the business or commercial purpose for processing the Personal Data.

When exercising the right to access Personal Data, you have the right to obtain materials in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

When we receive and verify your request to access your Personal Data, we will make best efforts to fulfill your request unless an exception applies. We will not disclose your government identification numbers, financial account numbers, health insurance or medical identification numbers, account passwords, security questions and answer, or unique biometric data; however, to the extent we have this information, we will inform you that we have collected this information. You are permitted 2 access reports every 12 months.

2.2 Right to request deletion of your Personal Data

You may also request that we delete any Personal Data that we obtained about you. However, we may retain Personal Data for certain important purposes, as set out by applicable law.

When we receive and verify your request to delete your Personal Data, we will proceed to delete the data unless an exception applies. We will retain a record of your deletion request in order to keep your Personal Data deleted, unless and until you provide consent for the processing of your Personal Data post your deletion request.

2.3 Right to correct your Personal Data

If you believe we hold inaccurate personal information about you, you may request that we correct that information. We may ask for documentation showing that the information you submit is accurate and the Personal Data we hold is inaccurate. Once we receive your request, we will verify your identity and taking into account the type of personal information and the purposes of our holding that personal information we will make best efforts to complete your request. We may deny your request if we determine that the contested Personal Data is more likely than not accurate. Additionally, we may choose to delete your Personal Data in response to your request to correct your Personal Data if the deletion of your Personal Data would not negatively impact you.

2.4 Right to limit use of Sensitive Personal Data

We do not collect Sensitive Personal Data as that term is defined in US state privacy laws like the California Consumer Privacy Act and the Virginia Consumer Privacy Act.

2.5 Right to nondiscrimination

We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise your privacy rights.

2.6 Right to Opt-out of the sale of your Personal Data.

Depending what information we have about you, and whether we have disclosed any of it to a third party in exchange for valuable consideration, we may have sold (as defined by US state laws) certain Personal Data about you, as described in the above relevant table in this Privacy Notice. If you would like to opt out, you may do so by clicking on the “Do Not Sell My Personal Information” link in the footer of this Website.

2.7 Right to Opt-Out of Share/Cross Contextual Behavioral Advertising and Targeted Advertising

We do not share your Personal Data for cross contextual behavioral advertising or otherwise engage in targeted advertising.

2.8 Right to opt-out of Automated Decision Making and Profiling

When processing your Personal Data, we do not use processes that involve automated decision making or profiling.

2.9 Universal Opt-Out Mechanisms

Our Website recognizes certain global opt-out of sale and share preference signals like the Global Privacy Control and the IAB CCPA privacy string/MSPA privacy string. This means that if you enact your choice to opt-out or opt-in through these signals, we will honor your choice upon receiving the signal related to your visit on our Website. We will apply your preference to the Personal Data we collected from our Website. If you have previously provided affirmative consent for the sale or share of your Personal Data, and your opt-out choice via the signal conflicts with such consent, we will ignore the opt-out choice via the signal.

2.10 Shine the Light

Customers who are residents of California may request (i) a list of the categories of Personal Data disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or contact form on our site as outlined in the “Further Information” section below and specify that you are making a “California Shine the Light Request.”

2.11 How to exercise your US state privacy rights

US residents may exercise their applicable privacy rights by sending an email to info@onnamedia.com, submitting your request on our contact form.

For security purposes (and as required under US state laws), we will verify your identity—in part by requesting certain information from you—when you make a request to access, correct, or delete, your Personal Data. The verification process will utilize an email verification process, a telephone number verification process, and, if applicable, a request for any assigned ID number previously communicated to you.

If we are unable to complete your request fully for any reason, we will provide you additional information about the reasons why we could not comply with your request.

You may also designate an agent to make requests to exercise your rights under certain US state laws. We will take steps both to verify your identity and to verify that your agent has been authorized to make a request on your behalf by requesting your agent to provide us with a signed written authorization or a copy of a power of attorney executed by you.

2.12 Appeal

It is your right to appeal a decision made concerning the exercise of your data privacy rights. You may appeal this decision within 60 days of receiving your response from us. To submit your appeal, contact info@onnamedia.com.

Applicability of Offline Information Collection.

If you are a California resident, this Privacy Policy also applies to information collected off of the Service. By using the Service or interacting with us offline you agree and consent to our information practices described in this Privacy Policy.

Additional Disclosures for Data Subjects in Europe

Subject to certain exceptions and the jurisdiction in which you live, if you are a resident of the EU, the GDPR provides you with specific rights regarding your Personal Data. This subsection describes your rights and explains how to exercise those rights regarding Personal Data that we hold about you. These rights include:

1.1 The right of access:

You can access all Personal Data we hold about you, know the origin of this Personal Data and obtain a copy in an understandable format.

You may also use your right to access your Personal Data to control the exactness of the data and have them rectified or deleted. You have no justification to provide to exercise your right to access;

1.2 The right to rectification:

In order to avoid that inaccurate or incomplete Personal Data relating to you is process or shared, you can ask us to rectify them;

1.3 The right to erasure:

You may request the erasure or deletion of the Personal Data we hold on you. This is not an absolute right since we may have to keep your Personal Data for legal or legitimate reasons. You may, for example, exercise your right to deletion in the following cases:

(a) if you have withdrawn your consent to the processing (see below);

(b) if you legitimately objected to the processing of your data (see below);

(d) the data is processed unlawfully (e.g., publishing hacked data);

1.4 The right to object to the processing of your Personal Data:

We process your Personal Data based on our legitimate interest (to determine to which processing this applies, please refer to the legitimate interest chart in this Privacy Notice), you may at any time object to the processing of your Personal Data for reasons relating to your personal situation. We may nevertheless, on a case-by-case basis, reject such a request by pointing out the legitimate and imperious reasons justifying the processing of this data which prevail on your interests, rights and freedoms, or when this data is necessary to establish, exercise or defend a right before a Court.

1.5 The right to restrict processing:

The right to limit the processing completes your other rights. This right means that the data processing relating to you and that we are performing is limited, so that we may keep this data, but we cannot use it or process it in any other manner. This right applies in specific circumstances, i.e.:

(a) if you challenge the exactness of your Personal Data. The processing is then limited for a period of time so that the agency may verify the exactness of the Personal Data;

(b) if the processing is unlawful and you object to the erasure of your Personal Data and request instead that its use be limited;

(c) if we do not need the Personal Data for the purposes mentioned above anymore, but you still need it to establish, exercise or defend rights before a Court; and

(d) in the cases where you objected to the processing which is based on the legitimate interests of the agency, you may ask to limit the processing for the time necessary for us to verify if we can accept your objection request (i.e., the time necessary to verify whether the legitimate reasons of the agency prevail over yours).

1.6 Right to object to data processing for direct marketing purposes

You may unsubscribe or object, at any time and without any justification, to the reception of direct marketing communications. Simply either (i) click on the link in the footer of the communications you receive from us; or (ii) use the hyperlink above; or (iii) send us an email at the email address set out in the “Further Information” section below with the word unsubscribe in the subject field of the email.

1.7 The right to data portability:

(a) You may request to retrieve the Personal Data you provided us with, in a structured, commonly used, and machine-readable format, for personal use or to share them with a third party of your choice.

(b) This right only applies to Personal Data you provided us with, directly or indirectly, and which was processed through automated means, if this processing is based on your consent or the performance of a contract. Please check the list of our Personal Data processing activities’ legal grounds to know whether our processing is based on the performance of a contract or on consent.

1.8 The right to withdraw your consent to the processing of your Personal Data at any time:

(a) You may read this Privacy Notice in order to identify the purposes for which the processing of your Personal Data is based on your consent.

(b) If you are unsatisfied with the way we process your Personal Data or if your request has been rejected, you may also lodge a formal complaint with your local competent data protection authority.

(c) Personal Data will be stored in accordance with our applicable data retention requirements and corporate policies. The retention period for Personal Data varies depending on the type of Personal Data and the purposes of processing it.

(d) We will respond without undue delay and in any event within one month from the data we receive your request. This timeframe can be extended by two months to take the complexity of the request, or the number of requests received into account. In this case, we will inform you within one month from receiving your request, specifying the reasons for extending the response timeframe

Roles.

Our Service is intended to provide information to our business clients and job applicants. You understand and agree that information collected about you is solely within the context of (i) your role as an employee, job applicant, owner, director, officer, or contractor or (ii) ONNA Media conducting due diligence regarding, or providing or receiving a product or service to or from your employer.If you are a California resident, see the sections entitled "Information on Behalf of Our Clients" above for information on how to exercise your rights.

Lawful Basis for Processing.

Data protection laws in Europe require a "lawful basis" for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers, partners, or clients; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests.

Your Data Subject Rights

If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us..

To exercise any of these rights, please e-mail us at info@onnamedia.com or send us a letter to the mailing address in the section entitled "Contact Us" above and specify which right you intend to exercise. We will respond to your request within 30 days. For information on how to exercise your rights for information collected and processed at the direction of our clients, see the section entitled "Information on Behalf of Our Clients" above. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfill the purposes for which it was collected, and may continue to retain and use the information even after a data subject request as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

If you have any issues with our compliance, you have the right to lodge a complaint with a supervisory authority.

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