Privacy Policy

How we use the information we obtain

We, or service providers acting on our behalf, may use the information collected from and about you to:

• Provide our services, including authorizing a purchase, or completing a transaction that you requested;
• Operate our business, comply with applicable laws, regulations and guidance, including federal, state, and local public health reporting; comply with demands or requests made by regulators, governments, courts and law enforcement authorities; and investigate and take action against illegal or harmful behaviour of users;
• Respond to inquiries from you and other third-parties, including inquiries from law enforcement agencies;
• Anonymize or de-identify personal information to provide third parties with aggregated data reports showing anonymized information and other non-personal information;
• Provide technical support;
• Generate suggestions about the type of content you may enjoy;
• Supplement your personal information collected directly from you and/or from automated means with additional information from publicly and commercially available sources, and/or information from our affiliates and our business partners;
• Provide you with content, products, or services that you request from us, create and service your account, manage your transactions and coordinate your services, administer promotions and user surveys, conduct research and analysis, contact you when necessary, fulfill any other purpose for which you provide it, carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for collection of payments, notify you about changes to our site, or any services we provide, perform any function needed with your consent;
• Protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities;
• Comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our terms of service and other policies; and
• In other ways for which we provide specific notice at the time of collection.

Information we collect and obtain

We obtain personal information about you from a variety of sources. This includes personal information you provide to us directly, information we obtain from other sources, and information we gather through automated means. Personal information collected shall not be limited to your name, phone number, e-mail, mailing address, date of birth, credit or debit card number for payment purposes, and other personally identifiable information that you choose to provide us with (“Personal Information”).

Usage Data & site Activity:

We may obtain personal information about you in connection with the Services from publicly and commercially available sources and from our affiliates and/or business partners (such as advertising networks or social networking services), including:

• Demographic data (such as gender, age range, educational level, household income range, number of children in household, ethnicity to the extent permitted);
• Occupational data (such as profession, position, title, industry; and business address);

Information Collected by Automated Means through Our Services. We may gather by automated means (such as cookies, web beacons, web server logs, JavaScript and other similar technologies) certain information through our Services:

• Your Internet Protocol (IP) address;
• Device information, including unique identifiers and connection information, including mobile device advertising IDs (e.g., Apple’s IDFA or Google’s AAID) and the means of internet connection (e.g., WiFi connection, ISP) that can identify the physical location of such devices, in accordance with applicable law;
• Your device type and settings, software used, browser type and operating system;
• Websites or other services you visited before and after visiting the Services (referring URL);
• Web pages and advertisements, you view and links you click on within, and what search queries you may have run on, the Services (clickstream);
• Viewing behavior, including the content you view, how long you view content, the quality of the service you receive, and advertisements you have been shown or interacted with;
• Dates and times, you access or use the Services

Cookies are small files that we or others send to and store on or with your computer so that your computer, browser, mobile app or other application can be recognized as unique the next time you access, visit, use or otherwise take advantage of the Services or other media. Cookies may also reflect demographic data pertaining to you or other data linked to information you submit. One use or consequence of cookies is to enable you to receive customized ads, alerts, content, services or information. You are always free to decline any cookies we use by adjusting the settings of your browser, as your browser may permit; however, some products, services or features might not be available or operate properly if cookies are not enabled. Some of our advertisers and third-party service providers may also utilize their own cookies.

Disclosure of Personal Information

In order to provide our services, we may share your Personal Information with businesses and service providers. We may form commercial relationships with other companies that we feel are trustworthy, including, but not limited to, Service Providers. We may, for example, hire Care Providers to offer services including hosting and maintenance, data storage and management, analytics, customer service, and marketing and promotions. We only give our Service Providers the information they need to conduct these services on our behalf. To safeguard your Personal Information from unauthorized access, use, or disclosure, each Service Provider must agree to employ reasonable security measures and practices according to the nature of the information involved. Other than as provided by us, Service Providers are not permitted to use Personal Information. Furthermore, we may enter into a commercial partnership with third-party firms and give them with the Personal Information they require to offer their services.

We may disclose your personal information to selected third parties, including:

• Third party service providers who perform services on our behalf, such as providers of IT and email distribution services, who may use your personal information for the purposes mentioned above;
• Advisors such as accountants, lawyers, and consultants;
• In the event that we sell or buy any business or assets, the prospective seller or buyer of such business or assets (and their respective advisers), who may use the personal information in connection with the sale or purchase;
• If Oren Access or substantially all of its assets are acquired by a third party, to the relevant third party (and its advisers) who may use the data in connection with the acquisition;
• Analytics providers that assist us in the improvement and optimization of our Websites;
• Law enforcement agencies or other third parties for the purposes described below.

Your Rights

California Rights:

Third-party Marketing and Selling. We do not provide your information to third parties for their direct marketing purposes.

Do Not Track. We may collect information about your usage and activity through cookies. Some web browsers or smartphones have the ability to set “Do Not Track” requests to block user activity from being tracked across web pages or devices. Our website does not recognize “Do Not Track” browser signals.

Other Privacy Rights.

All Your Personal Information we collect will always belong to you. However, we are a collector and a processor of Your Personal Information. That implies on us obligations to respect your rights to Personal Information and facilitate the exercise of your rights thereto. In order to use any of your rights at any time please contact us and we will facilitate the exercise of your rights free of charge. We will inform you on the actions taken by us under your request as soon as practically possible, but in any case, not later than in 30 (thirty) calendar days.

In accordance with effective regulations, particularly the GDPR, you have a significant number of rights related to your Personal Information, such as e.g.:

• Right to access. You may obtain from us the confirmation as to whether or not personal data concerning you is being processed and get an access to such personal data. You are entitled to view, amend, or delete the personal information that we hold. Email your request to our data protection office at support@orenaccess.com and we will work with you to remove any of your personal data we may have.
• Right to rectify your inaccurate Personal Information and to have incomplete personal data completed, including by means of providing a supplementary statement
• Right to erase your Personal Information. Please note that a request to erase your Personal Information will also terminate your account on the Site. We will automatically and without undue delay erase your Personal Information when it is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
• Right to restrict processing of your Personal Information;
• Right to data portability. You may obtain from us the personal data concerning you and which you have provided to us and transmit it to another Personal Information Controller;
• Right to object to processing of Your Personal Information;
• Right to withdraw your consent to the usage of your Personal Information at any time;
• Right to lodge a complaint. We take privacy concerns seriously. If you believe that we have not complied with this Privacy Policy with respect to your Personal Information, you may contact our respective Data Protection Office. We will investigate your complaint promptly and will reply you within 30 (thirty) calendar days.

Analytics

When someone visits the website, we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to track things such as the number of visitors to the various parts of the site and interactions with the site. This information is processed in a way which does not identify anyone. We do not make and do not allow Google to make, any attempt to find out the identities of visitors to our website.

Securing Privacy

To transfer data between our websites, our applications and backends, communication is encrypted using the SSL (Secure Socket Layer) encryption. We protect the systems and processing by a series of technical and organizational measures. These include data encryption, pseudonymization and anonymization, logical and physical access restriction and control, firewalls and recovery systems, and integrity testing. Our employees are regularly trained in the sensitive handling of personal data and are obliged to observe data secrecy in accordance with legal requirements.

Minors

We do not knowingly gather or otherwise process personal data of minors under the age of 18. If we notice that one of our users/visitors is a minor we’ll immediately take steps to remove their information. If you believe we have processed or still hold information on minors, please send us an email at support@orenaccess.com and we’ll remove it A.S.A.P.

Changes in the Privacy Statement

The effective date at the top of this page indicates when this Privacy Statement was last revised. We will notify you before any material change takes effect so that you have time to review the changes. Any change is effective when we post the revised Privacy Statement. Your use of the Services following these changes means that you accept the revised Privacy Statement.