We respect your privacy and care about how your Personal Information is used. This Privacy Policy (the “Policy”) outlines how Omicron Group Solutions LLC (“Company” or “us” or “we” or “our“) including our affiliates and our third-party service providers such as our payment gateway partner, Stripe collect, use, store, process, transfer, and disclose your information through our Website https://omicrongs.com/ (“Website”), our web application https://app.omicrongs.com/ (“Software”), our product Taskia (“Product”) accessible through taskia.app or taskia.omicrongs.com, our AI-powered services (“AI Services”) integrated within the Software and Product, our Services, or any other services we offer from time to time by or in connection therewith (the “Platform” or “Omicron”). At our Platform, we believe in integrating diverse perspectives into our systems, providing comprehensive solutions to streamline organizational management in ever-evolving environments. Our commitment to privacy ensures that your information is safeguarded as we navigate dynamic landscapes together. The Software allows you to manage from a single place the contact information of your collaborators, the structure and job profiles of your company, as well as your strategic planning (the “Services”). By reviewing this Policy, you will gain a comprehensive understanding of your privacy rights and choices.

Your access to or utilization of our Platform and/or Services operated by the Company linked to this Policy implies your agreement to be governed by this Policy. By providing us with your Personal Information, you expressly consent to the use and disclosure of your Personal Information as outlined in this Policy. This Policy, along with the other policies and the Terms of Service, is applicable to your use of the Services and you explicitly agree and acknowledge to read the Privacy Policy in conjunction with the Terms of Service.

The term “Personal Information” shall mean any information that relates to an identified or identifiable individual, and can include information that you provide to us and that we collect about you, such as when you engage with our Platform and/or Services (e.g. device information, IP address, location etc.).

By utilizing the Platform and/or Services, or furnishing your Personal Information, you explicitly agree and acknowledge that you accept the terms delineated in this Policy. The terms ‘you‘ or ‘your‘ in the context of this Policy collectively pertain to any user of our Platform or any individual utilizing our Services, whether for personal use or on behalf of others.

By visiting the Platform or providing your information, you expressly agree to be bound by this Privacy Policy and agree to be governed by the privacy laws of the United States including but not limited to the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other relevant regulations governing data protection and privacy.

IF YOU DO NOT CONSENT TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS SET FORTH IN THIS PRIVACY POLICY, PLEASE REFRAIN FROM ACCESSING AND/OR USING OUR PLATFORM.

     1.         TO WHOM DOES THIS POLICY APPLY?

1.1.         This Policy is inclusive and applies to all users of our Platform and/or Services, irrespective of their browsing intent or their extent of utilizing the Services offered on our Platform.

1.2.         The applicability of this Policy extends to users regardless of the device type used for accessing our Platform and/or Services, whether it be a laptop/desktop or a mobile/tablet device.

1.3.         We do not knowingly collect or solicit Personal Information from anyone under the age of eighteen (18) or knowingly allow such persons to register for and/or utilize the Services. If you are under the age of eighteen (18), please do not attempt to register for the Services or send any information about yourself to us. No one under the age of eighteen (18) may provide any Personal Information to us.

     2.         WHAT IS THE INFORMATION THAT WE COLLECT FROM YOU?

2.1.         To utilize the Platform and our Services, you must complete the one-time sign-in process with us by setting up a user account (the “Account”). To create an Account, you must provide certain information. This may include but is not limited to the following:

2.1.1.         Basic Information: You are required to provide basic information such as full name and a password while setting up the Account. While utilizing the Software you may optionally provide us with other details such as an address, employee information, birthday, gender etc. You can also update information relating to your company including projects, tasks, salaries, organizational structure etc

2.1.2.         Contact information: such as email address;

2.1.3.         Verification Data: We may collect information relevant to your use of our Platform and Services, such as a 4-digit verification code sent at the time of Account creation, and sign-up to the email address provided by you. Additionally, as part of our verification mechanism, we may collect information to authenticate your identity, which may include undergoing an email verification process. If you activate two-factor authentication (2FA), you will receive another code every time you log in to verify your access to the registered email;

2.1.4.         Transaction Data: including the details of the payment method such as credit or debit card number, and bank account information. Please note that we do not collect the transaction data directly but our payment partner Stripe does. You agree that in providing such transaction data, you consent to the privacy policy of Stripe which can be found here https://stripe.com/in/privacy.

2.1.5.         Sensitive Personal Information: Through our Platform and on the Software, you may store personal and sensitive information such as social security numbers, contact numbers and other Personal Information of yourself and others;

2.1.6       Interaction with AI Services: When you interact with our AI Services, we collect your input data such as your text queries, contact information, or other relevant data that you may provide while utilizing the AI services. Further, we also collect the outputs generated by AI based on your inputs, including responses and personalized insights. Additionally, metadata related to your interactions such as timestamps or frequency of use is gathered to monitor, train, and improve our AI Services model.

2.1.7.         Additional Information: It includes without limitation, when you fill in information through our payment partner, Stripe, or make payments through Stripe, participate in promotions, communicate with the Omicron support team and other users, import or manually enter address book contacts, provide your address and/or geolocation, or share your experience with us;

2.1.8.         Communication with us: This can include any communication that you send to us, including communications for any inquiries, payments, technical support, etc;

2.1.9.         Device Identification data: This includes information that may assist us in identifying your device, including browser type, and version, your operating system, etc;

2.1.10.         Other Data: This can include the following, based on your interaction with the Platform and/or Services-

a.     Number of times you access our Platform and/or Services;

b.     The length of time you spent on the Platform;

c.     The period of time from when you became active and have continued to be active on the Platform;

d.     Other similar statistics we may collect with the intention to improve the user experience of the Platform.

2.2.         You agree to provide us and our payment partner, Stripe with your Personal Information whenever you use our Services by performing any of the following functions:

2.2.1.         Accessing our Platform and/or Services by means of any web browser or any device;

2.2.2.         Signing in for our user plans and registering for our Services;

2.2.3.         Inquiring about our Services through our Platform;

2.2.4.         Initiating and maintaining correspondence with us.

2.2.5       Interacting with our AI Services which includes inputting data, receiving AI-generated outputs, and engaging with personalized recommendations and insights..

2.3.         You understand and agree that we do not directly collect Personal Information from users and all sensitive Personal Information collected through our Platform is introduced solely by the user. We do not collect any personal or sensitive information without the user’s explicit input and consent. Users are responsible for the accuracy and completeness of the information they provide. By using our Services, you acknowledge that you are bound by the terms and policies of our third-party service providers such as our payment processor Stripe and storage partner AWS. We prioritize user privacy and security by relying on trusted third-party service providers, and we encourage users to review and understand the policies of these platforms to protect their interests.

2.4.      Further, you understand and acknowledge that we provide advanced AI Services to our users within the Software and/or Product to enhance the functionality of our offerings. For providing such AI Services, we utilize ChatGPT API services provided by OpenAI. While we manage your Personal Information in accordance with this Policy, you are encouraged to review OpenAI’s policies that govern our use of ChatGPT API services, including but not limited to terms and conditions, privacy practices, and usage policies to understand how OpenAI handles your input and output data. By utilizing our AI Services, you also agree to be bound by these Open AI policies. We prioritize user privacy and security by relying on trusted third-party service providers, and we encourage users to review and understand the policies of these platforms to protect their interests.

2.5.         You understand that our payment partner, Stripe provides you with the convenience of storing your payment methods on the Platform. By opting for this feature, you consent to the storage of your Personal Information, including your payment method.

2.6.         Users also have the option to subscribe to our newsletter at the time of Account registration or through our Website at any time later, allowing them to stay informed about our latest updates and offerings.

2.7.         We strive to take extra precautions to ensure that such Personal Information is kept secure and confidential, and we will only retain this data for as long as necessary for the purposes for which we collect it as per the permissible laws of the land.

2.8.         This Policy will not apply to any unsolicited information provided by you through the Platform or through any other means. This includes but is not limited to, information posted on any public areas of the Platform. All such unsolicited information shall be deemed to be non-confidential and we will be free to use and disclose such unsolicited information without limitation.

2.9.         We shall not be liable for any loss or damage sustained by you as a result of any disclosure (inadvertent or otherwise) of any Personal Information concerning your payment-related information in the course of any online transactions or payments made for any Services offered through the Platform. For this purpose, we recommend that you go through the terms of service of our payment service provider, Stripe which can be found here https://stripe.com/in/legal/consumer.

2.10.         Access to your Personal Information is limited to employees, agents, partners, and third parties, who we reasonably believe will need that information to enable us to provide Services to you. However, we are not responsible for the confidentiality, security, or distribution of your own Personal Information by our partners and third parties (who have their own privacy policies) outside the scope of our agreement with such partners and third parties.

2.11.         When you use our Platform, we collect and store your information which is provided by you from time to time. In general, you can browse the Platform without telling us who you are or revealing any Personal Information about yourself. Once you give us your Personal Information, you are not anonymous to us. Where possible, we indicate which fields are required and which fields are optional. You always have the option to not provide information by choosing not to use a particular service, product, or feature on the Platform.

     3.         HOW DO WE COLLECT THE INFORMATION?

3.1.         We employ various methods to gather information, ensuring a comprehensive understanding of user interactions and preferences. The collection of Personal Information is facilitated through the following processes:

3.1.1.         Information you give us: When you provide us with the information referred to in Clause 2.1 through the methods outlined in Clause 2.2;

3.1.2.         Session Management: We study session metrics to understand how users interact with the Platform. This helps us learn the average time users spend on the Platform and when they prefer to engage. We use tools like Google Analytics (or alternatives) to collect anonymous data, including the number of views, how long users stay, and where they’re visiting from. This data allows us to optimize the user experience, making informed enhancements to cater to user preferences and behaviors;

3.1.3.         User analytics: We analyze user behavior and preferences, by collecting and analyzing Personal Information and maintaining transaction history within the Platform to track and ensure accuracy, promptly identify any unauthorized transactions, and detect fraudulent activities, allowing us to take immediate corrective action.

3.2.         In addition to direct user interactions, we leverage cookies and similar technologies to enhance the functionality and user experience on the Platform. These allow us to collect and process additional information for various purposes:

3.2.1.         Cookies: We utilize cookies, which are small text files stored on users’ devices. These cookies assist in tracking user preferences, optimizing Platform functionality, and providing a customized experience. Users have the option to manage cookie preferences outlined through their browser settings. Below are the categories of cookies used on our Platform along with a description of what they are used for:

3.2.1.1.         Strictly Necessary Cookies: These cookies are needed to run our Platform, to keep it secure if you are logged in, and to obey regulations that apply to us. They also help us keep your details safe and private;

3.2.1.2.         Functional Cookies: These cookies are used for remembering things such as your region or country, your preferred language, accessibility options like large font or high-contrast pages;

3.2.1.3.         Performance Cookies: These cookies tell us how you and our other users use our Platform. We combine all this data together and study it. This helps us to improve the performance of our Services and/or the Platform;

3.2.2.         Web Beacons, Pixel Tags, and Trackers: We may employ Web Beacons, Pixel tags, and tracking URLs which are tiny graphic images and/or small blocks of code placed on Website pages, ads, or in our emails that allow us to determine whether you performed a specific action. When you access these pages, or when you open an email, you let us know that you have accessed the web page or opened the email. These tools help us measure responses to our communications and improve our web pages and promotions;

3.2.3.         Log Files: Our servers automatically collect information sent by users’ devices, known as log files. This data may include IP addresses, device information, browser type, and timestamps. Log files are instrumental in analyzing trends, administering the Platform, and diagnosing technical issues;

3.2.4.         Third-Party Analytics: We may integrate third-party analytics services to further understand user behavior. These services utilize their own tracking technologies to compile reports on Platform activity, aiding us in improving our Services;

3.2.5.         Location Data: As part of our Services we may also collect precise geolocation data, including GPS signals, device sensors, Wi-Fi access points, and cell tower IDs. We collect this type of data if you grant us access to your location. You can withdraw your consent at any time by disabling the GPS or other location-tracking functions on your device;

3.2.6.     Metadata: When you interact with our AI Services, we collect metadata to enhance and optimize the service experience. This metadata includes details such as interaction timestamps, query types, response times, technical data (e.g., IP addresses, device identifiers), and usage patterns. This information helps us analyze user behavior, refine our AI Services, and improve overall service performance. All metadata is used solely for operational purposes and service improvement.

3.2.7.     Information from other sources: We may collect Personal Information from other sources, including but not limited to:

3.2.7.1.         If a user or any third party submits a complaint about you, we may receive information relating to the specific complaint made in order to understand and, where relevant, address the complaint; and

3.2.7.2.        To the extent permitted by applicable law, we may receive additional information about you, such as references, demographic data, and information to help detect fraud and safety issues from (i) third-party service providers, other third parties, and/or partners, or (ii) users and any other individuals, entities, and authorities, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from identity verification service providers for use in our fraud prevention, security investigation, and risk assessment efforts. We may receive information about you and your activities on and off the Platform, including from users of Omicron, members of the public, or governmental, public, or tax authorities, or about your experiences and interactions with our partners. We may receive health information including, but not limited to, health information related to contagious diseases.

     4.         WHY DO WE COLLECT YOUR INFORMATION?

4.1.         We shall collect your information only for lawful and legally permissible purposes which are as follows:

4.1.1.         User Authentication: We collect your information to help us identify you as and when you access the Platform, when you register an Account with us or log in, or when you utilize our Services. This includes but is not limited to resetting Account passwords or approving special consideration applications;

4.1.2.         Communicate with you: We use your Personal Information to communicate with you concerning Services via different channels (e.g., by phone, e-mail, chat) including to fulfill your requests when you subscribe to our user plans;

4.1.3.         Fraud Prevention and Credit Risks: We use your Personal Information to prevent and detect fraud and abuse to protect the security of our users;

4.1.4.         Troubleshoot Problems: We use your Personal Information to provide functionality, analyze performance, fix errors, and improve the usability and effectiveness of the Platform and/or Services;

4.1.5.         Compliance with law: To be able to perform any contractual and legal obligation;

4.1.6.     AI Services Model Training and Improvement: To continuously improve our AI Services model and algorithms, we collect data from your interactions with our AI Services. This includes analyzing user inputs and AI-generated outputs to refine the accuracy and relevance of our AI Services responses. By studying how users engage with our AI Services, we can identify patterns, correct inaccuracies, and enhance the overall performance of our AI features. Additionally, your data helps us develop new features and improve existing ones. For instance, we use the insights gained from user interactions to innovate and enhance our AI capabilities, ensuring they meet user needs more effectively. Further, you understand that any Personal Information you provide through our Platform is used solely for the purpose of enhancing and managing the AI Services provided by Omicron. It is not used for training or improving OpenAI’s models. OpenAI’s role in our services is limited to providing the underlying technology that powers our AI capabilities. We ensure that your Personal Information is used exclusively to improve the AI Services offered by Omicron, not for training OpenAI’s models.

4.1.7     AI Services Performance Monitoring: To ensure that our AI Services function as intended, we collect and review data to monitor performance metrics. This helps us detect issues, assess the quality of AI-generated responses, and make necessary adjustments to improve user experience.

4.1.8.         Enhancing User Experience: To analyze user behavior and preferences for improving our Services and user experience and to be able to provide location-specific services;

4.1.9.         Recommendations and Personalizations: We use your Personal Information to recommend features, products, and Services that might be of interest to you, identify your preferences, and personalize your experience with the Platform and/or Services;

 4.1.11.         Enhanced Advertising and Marketing Efforts: In our efforts to provide, personalize, measure, and enhance our advertising and marketing endeavors, we engage in several key activities. Firstly, we utilize user information to send promotional and marketing messages, tailoring them to suit individual preferences and interests. Additionally, we strive to customize and optimize advertising on various platforms to ensure relevance and effectiveness. Furthermore, we may administer referral programs, rewards, surveys, sweepstakes, contests, and other promotional activities to engage users and foster community participation. Through the analysis of user characteristics and preferences, we aim to send targeted promotional messages that resonate with each user segment. Finally, we extend invitations to users for events and relevant opportunities, enriching their overall experience with our Platform; and

4.1.12.         Providing alerts/notifications: To effectively communicate with you through emails/SMS/notifications through the Platform to inform you about any other new Services that we may from time to time develop.

4.2.         In the course of operating the Platform and/or Services, we collect and utilize Personal Information in accordance with our Privacy Policy. For users residing in California, Colorado, Connecticut, Delaware, Florida, Iowa, Montana, Nevada, Oregon, Texas, Utah, Vermont, Virginia, or Washington, or are otherwise protected by privacy or consumer health data laws in those jurisdictions, please refer to Schedule 1 that supplements our main Privacy Policy and outlines state-specific rights and protections afforded to you.

4.3.         For the users residing outside the United States, specific provisions and disclosures may apply, as detailed in our Supplemental Document (See Schedule 2). This document provides comprehensive information regarding the processing of Personal Information, including details about responsible controllers, legal bases, user rights, and contact information for inquiries. By referencing this Supplemental Document, users gain insights into our compliance with regulations such as the General Data Protection Regulation (GDPR) and gain transparency into how their information is handled.

4.4.         You consent and recognize that your Personal Information may be disclosed on our Platform authorized by you for the purpose of utilizing our Services. Additionally, you agree and acknowledge that we are permitted to communicate with you through messaging, calls, emails, or other means, to facilitate the performance of our Services wherever necessary.

     5.         WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH AND WHY?

5.1.         To facilitate our Services and enhance user experience, we may share Personal Information with the following entities:

5.1.1.         Payment Partners: We may share your Personal Information necessary for transaction processing with our trusted financial or payment gateway partner and storage partner;

5.1.2.         Third-party Service Providers: We engage the services of third parties to carry out various functions on our behalf such as payment processing, data analysis, postal and email communications, hosting services, storage, customer service, and marketing assistance. While these third-party service providers have access to the necessary Personal Information to fulfill their functions, they are prohibited from using it for any other purposes. Moreover, they are obligated to process the Personal Information in compliance with applicable laws. We utilize Amazon Web Services (AWS) for a range of services, including databases, servers, SSL certificates, and file storage (S3 Buckets). While we do not own or control these third parties, when you interact with them and choose to use their services, you are providing your information to them. Your use of these services is subject to the privacy policies of those providers, including Stripe’s Privacy Policy and AWS Privacy Policy. Further, you acknowledge that our AI capabilities are powered by OpenAI, which provides the underlying technology for our AI Services. While we do not share any data directly with OpenAI but OpenAI accesses your inputs to respond to your queries and deliver the AI functionalities. However, OpenAI does not retain any data from these interactions unless required by law. Their policy ensures that data sent via the API is processed solely for operational purposes such as monitoring for abuse, ensuring service reliability, or conducting research. Importantly, your data remains confidential and is not used by OpenAI for model improvement or training.

5.1.3.         Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates may include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us;

5.1.4.         Business Transfers: If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity.  If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party.  You acknowledge that such transfers may occur and that the transferee may decline to honor commitments we made in this Privacy Policy.

5.1.5.         Legal Compliance:

5.1.5.1.         We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, authorized third parties, or other users, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary to: (i) comply with our legal obligations, (ii) comply with a valid legal request, such as a subpoena or court order, or to respond to claims asserted against Omicron, (iii) respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability, (iv) enforce and administer our agreements with users, including our Terms, additional legal terms, and policies, (v) respond to requests for or in connection with current or prospective legal claims or legal proceedings concerning Omicron and/or third parties, in accordance with applicable law, or (vi) protect the rights, property or personal safety of Omicron, its employees, its user, or users of the public;

 5.1.5.2.         Where legally required or permissible according to applicable law, we may disclose user information to relevant tax authorities or other governmental agencies, depending on where you are based, for the purpose of the tax authorities’ determination of proper compliance with relevant tax obligations;

5.1.5.3.         Where appropriate and/or legally required, we may notify the user about legal requests, unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon or harm to Omicron, our users, or expose Omicron to a claim of obstruction of justice.

5.1.6.         Service Improvement: We may share certain aggregated, anonymized information with third parties (for example, for Google Analytics) in order to assess the Platform usage and information pertaining to the ease of navigation;

5.1.7.         Advertisements: We use third-party advertising companies to serve ads when you visit our Platform. These companies may use information (not including your name, address, email address, or telephone number) about your visits to the Platform and other websites in order to provide personalized advertisements about goods and services of interest to you;

5.1.8.         Collaborations: We may share your Personal Information with reputable partners to facilitate joint initiatives, promotions, or integrated services; and

5.1.9.         Growth and Expansion: As our Platform evolves and expands, there may be instances where sharing Personal Information with new entities or parties becomes necessary for the enhancement of our Services. Any such sharing will be carried out with the utmost consideration for user privacy and in accordance with relevant legal frameworks.

5.2.         We do not ever sell or rent your Personal Information without your express approval.

5.3.         We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

     6.         HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

6.1.   Your Personal Information is stored and retained by us until you cease payment for the Services provided. Upon cessation of payment, your Account will be transitioned to the Free Plan, which is offered free of charge indefinitely. In the event that you transition to the Free Plan and exceed the features and limitations of this plan, we reserve the right to maintain the data for a period of six months from the transition date. Should you choose to delete your Account voluntarily, we will immediately delete the associated data.

6.2.    However, certain data related to you may be retained beyond this period if we reasonably believe it is necessary to prevent fraud, mitigate potential abuse, allow us to exercise our legal rights, defend against legal claims, or fulfill other legitimate purposes required by law or for analytical and research purposes. Additionally, we may continue to retain your Personal Information for the following purposes including but not limited to:

6.2.1.         Legitimate Business Interest: We may retain your Personal Information as necessary for our legitimate business interests, such as the prevention of money laundering, fraud detection and prevention, and enhancing safety;

6.2.2         Legal, Tax, Reporting, and Auditing Obligations: We may retain and use your Personal Information to the extent necessary to comply with our legal, tax, reporting, and auditing obligations;

6.2.3         Shared Information: Information you have shared with others, such as reviews and forum postings, may continue to be publicly visible on the Platform, even after your Account is canceled; and

6.2.4.         Residual Copies: Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your Personal Information may not be removed from our backup systems for a limited period of time.

6.3.    Further, you acknowledge that our AI capabilities are powered by OpenAI, which provides the underlying technology for our AI Services. While we do not share any data directly with OpenAI but OpenAI accesses your inputs to respond to your queries and deliver the AI functionalities. However, OpenAI does not retain any data from these interactions unless required by law. Their policy ensures that data sent via the API is processed solely for operational purposes such as monitoring for abuse, ensuring service reliability, or conducting research. Importantly, your data remains confidential and is not used by OpenAI for model improvement or training.

     7.         HOW DO WE PROVIDE FOR THE SECURITY OF YOUR PERSONAL INFORMATION WITH US?    

7.1.  Storage Information: User data is stored on our secure Amazon Web Services (AWS) servers and databases. These servers are strategically located based on the user’s location to minimize latency for each user.

7.2. Database Protection Measures: Our databases are accessible solely through our Virtual Private Network (VPN) and restricted to computers within that network. We enforce internal policies, including:

7.2.1. Regular rotation of main passwords with access restricted to a select group within the company.

7.2.2 Implementation of Two-Factor Authentication (2FA) for access to AWS services.

7.2.3 Access to the production database is limited to specific team members authorized by the company.

7.2.4 Stringent development policies across all system components (Frontend, Backend, and Database) to prevent data mixing or loss.

7.2.5 Implementation of backup policies and retention policies to safeguard data integrity.

7.3. You understand and agree that despite the security measures in place, Omicron cannot be held liable for any issues related to data security. Nevertheless, we implement reasonable physical, electronic, and procedural safeguards to maintain the confidentiality and integrity of your information. As part of this commitment, it is imperative that you also review and adhere to the terms of service and privacy policy of our third-party service providers. 

7.4.  While we take comprehensive measures to safeguard your information, by using our Platform and/or Services, you accept and understand the security implications inherent in transmitting data over the Internet and the World Wide Web. Despite our diligent efforts, complete security cannot be guaranteed, and inherent risks persist. Rest assured, we are dedicated to continuously enhancing our security protocols to effectively mitigate emerging threats and uphold the trust of our users.

     8.         HOW DO WE HANDLE DATA BREACHES AND SECURITY INCIDENTS?

8.1.         In the event of a data breach or security incident, Omicron maintains a proactive approach to ensure swift resolution and mitigate potential risks. We have established a comprehensive incident response plan designed to address such occurrences promptly and effectively:

8.1.1.         Identification: We promptly identify and acknowledge any signs of a data breach or security incident within our systems or infrastructure;

8.1.2.         Containment: Immediate action is taken to contain the impact of the breach, preventing further unauthorized access or damage to data;

8.1.3.         Notification: We prioritize transparency by promptly notifying affected parties, including users and relevant stakeholders, about the breach and its potential impact on their data;

8.1.4.         Collaboration: Omicron collaborates with relevant authorities, such as regulatory bodies and law enforcement agencies, to report the incident and comply with any legal obligations or regulatory requirements; and

8.1.5.         Post-Incident Assessment: Following the resolution of the incident, we conduct thorough assessments to evaluate the effectiveness of our response measures and identify areas for improvement.

     9.         DO WE TRANSFER YOUR PERSONAL INFORMATION ACROSS THE BORDER?

9.1.         While our primary practice is to store all data on servers located within the United States, it’s important to note that certain circumstances may necessitate the transfer of your Personal Information to countries outside your residential country. These transfers may occur for various purposes outlined in this Policy. To reduce latency for our users located in Europe, Asia, and Oceania, we expect to work with Amazon Web Services (AWS). This involves data transfer, which will be managed by AWS.

9.2.         You understand and accept that other countries may have differing (and potentially less stringent) laws relating to the degree of confidentiality afforded to the information it holds and that such information can become subject to the laws and disclosure requirements of such countries, including disclosure to governmental bodies, regulatory agencies, and private persons, as a result of applicable governmental or regulatory inquiry, court order or other similar processes. In addition, a number of countries have agreements with other countries providing for the exchange of information for law enforcement, tax, and other purposes.

9.3.         If we transfer your Personal Information to third parties for purposes stated in this Policy, we will use our best endeavors to put in place appropriate controls and safeguards to ensure that your Personal Information is kept accurate, adequately protected, and processed only for specified and reasonable purposes in a manner that is fair, transparent and has a lawful basis, and is stored for no longer than is absolutely necessary.

  10.         WHAT ARE YOUR RIGHTS AS A DATA SUBJECT?

10.1.         You, as a data subject, have certain rights to your Personal Information with us, as under:        

10.1.1.      Right to Access: You have the right to access any of the Personal Information we hold about you at any time. For security purposes, when you request access to your Personal Information, you will need to provide us with enough information to verify your identity. We will generally provide you with access to your Personal Information, subject to some exceptions permitted by law. If we are unable to provide you with all or any of the information we hold about you, we will inform you why your request has been denied or limited.;

10.1.2.         Right to withdraw consent: The consent that you provide for the collection, use, and disclosure of your Personal Information will remain valid until such time it is withdrawn by you in writing. You may withdraw your consent at any time by contacting us. Upon withdrawal, we will cease processing the relevant personal information, except where other legal grounds for processing exist under applicable laws. We will respond to your request within a reasonable timeframe;

10.1.3.      Opting Out of Marketing Materials: You may object to our use of your Personal Information for marketing purposes. You can always opt out of this through the functionality provided in each marketing communication (e.g. by clicking “unsubscribe” at the bottom of an email).

10.1.4.         Right to correction: You are responsible for maintaining the accuracy of the information you submit to us. If you wish to make a request to correct or update any of the Personal Information that we hold about you, you may update your information by writing to us;

10.1.5.         Right of Access and Portability: In some jurisdictions, applicable law may entitle you to request certain copies of your Personal Information or information about how we handle your Personal Information, request copies of Personal Information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another service provider, where technically feasible.

10.1.6.         Right of Erasure: In some jurisdictions, you can request that your Personal Information be deleted;

10.1.7.         State-Specific Rights: For users residing in California, Colorado, Connecticut, Delaware, Florida, Iowa, Montana, Nevada, Oregon, Texas, Utah, Vermont, Virginia, or Washington, or are otherwise protected by privacy or consumer health data laws in those jurisdictions, please refer to Schedule 1 that supplements our main Privacy Policy and outlines specific rights afforded to you as a data subject;

10.1.8.         User’s Rights Outside United States: For the users residing outside the United States, please refer to Schedule 2 which provides for user rights, safeguards for international data transfers, and contact information for inquiries.

  11.         ARE CHILDREN ALLOWED TO USE OUR PLATFORM AND/OR SERVICES?

11.1 This Platform and/or Services are strictly prohibited for use by individuals under the age of eighteen (18) years old (“Minors“). Accessing or using the Platform and/or Services by Minors constitutes a violation of our Terms of Service and Privacy Policy.

11.2 We do not knowingly solicit, collect, or process any Personal Information from Minors. If you are a parent or legal guardian (“Guardian“) and believe your child has provided us with Personal Information, we urge you to promptly contact us at compliance@omicrongs.com. Upon verification of your Guardian status, we will promptly take all necessary steps to remove and delete such information from our records.

  12.         HOW CAN YOU EXPRESS YOUR COMPLAINTS AND CONCERNS?

User satisfaction is one of the key focus areas and an integral part of our Platform’s founding principles and business policies. We strongly believe that user satisfaction is the most important factor in the growth and development of our business and hence, we have adopted user-centricity as a priority in developing our business processes. The terms below shall constitute our “User Grievance Redressal Policy” which outlines the framework for addressing user grievances:

12.1.         Objective: The objective of this Grievance Policy is to provide a framework:

12.1.1.         to ensure the provision of timely and effective resolution of issues raised by users; and

12.1.2.         to keep users informed about the manner in which they can reach out to us to resolve their queries and grievances.

12.2.         Governing Principles: The policy on grievance redressal is governed by the following principles:

12.2.1.         User shall be treated fairly at all times;

12.2.2.         Issues raised by users are always attended to with courtesy and on time;

12.2.3.         Users are provided with effective and satisfactory resolution within a reasonable time period; and

12.2.4.         Users are fully informed of avenues to escalate their issues/ grievances if they are not fully satisfied with the response to their complaints.

12.3.         User Support: Any user can reach out to our user support team/ representative through electronic mode by way of email communication at support@omicrongs.com; 

12.4.         Must Know: You must know and understand that:

12.4.1.         We DO NOT solicit confidential details like your OTP/CVV/PIN/Card Number/ Bank account details through any means.

12.4.2.         Scamsters/fraudsters attempt various techniques such as ‘phishing’, to contact, influence, and defraud consumers. We regularly caution our users against sharing any personal or payment-sensitive information with unknown persons as such sharing leads to unauthorized use and/or fraud and consequent financial loss.

12.4.3.         We shall not be liable for any loss, damage, or expense incurred by a user where the user has shared personal and/or payment-sensitive information with scamsters/fraudsters.

12.4.4.         Additionally, we also request and encourage our users to report such attempts or incidents to us at support@omicrongs.com  to enable us to investigate and explore legal recourse.

12.4.5.         We rely on payment partners and banks. In certain cases involving payment/refund issues, we might see a delay as that is beyond our control once we pass the investigation to them; however, we try our best not to exceed reasonable timelines.

  13.         HOW ARE CHANGES MADE TO THIS POLICY?

This Policy may be updated at our sole discretion or due to changes in the law. Such changes, unless otherwise stated, will be effective from the day and date of posting on the Platform. We reserve the right to update the Policy without obligation to notify users. It is recommended to regularly review this Policy for any changes, as your continued access and use of the Platform and/or Services will be considered your approval and acceptance of all modifications to this Policy. In cases where applicable law mandates, we may notify you of updates through email. If you do not agree with this Policy governing our Platform and/or Services, please refrain from using the Platform and/or Services provided by us.

  14.         HOW CAN YOU CONTACT US?

Should you need additional information or have any questions or complaints regarding the handling of your Personal Information, please reach out to us in writing at:

Email: compliance@omicrongs.com

Schedule I- Privacy Policy Supplement for Specific Jurisdictions

If you reside in California, Colorado, Connecticut, Delaware, Florida, Iowa, Montana, Nevada, Oregon, Texas, Utah, Vermont, Virginia, or Washington, or are otherwise protected by privacy or consumer health data laws in those jurisdictions, this section supplements our main Privacy Policy and outlines specific rights and protections afforded to you.

A. Your Privacy Rights:

●      Right to Access: You have the right to request access to your Personal Information, including details about how it is collected, used, and shared by Omicron. Upon request, we will provide this information in a portable and readily usable format, subject to verification of your identity;

●      Right to Correction: You have the right to correct any inaccuracies in your Personal Information held by Omicron. You can submit a verifiable request for correction, and we will promptly update your information as needed;

●      Right to Deletion: You may request the deletion of your Personal Information from Omicron’s records, subject to certain exceptions permitted by law. We will comply with your request, provided it does not conflict with our legal obligations or legitimate business interests;

●      Right to Opt-Out: You have the right to opt out of certain processing activities, such as the sale of Personal Information or the use of Personal Information for targeted advertising purposes. Omicron will respect your preferences and refrain from such activities upon your request. 

B. Appeals Process:

If you disagree with Omicron’s response to your privacy rights request or believe your rights have not been adequately addressed, you have the right to appeal. You can submit your appeal in writing to our Data Protection Team at compliance@omicrongs.com with the subject line “Appeal of Privacy Rights Request.”

C. Data Retention and De-Identification:

Omicron is committed to retaining Personal Information only for as long as necessary to fulfill the purposes for which it was collected, as outlined in our main Privacy Policy (see Clause 6). We will also take measures to de-identify personal information in accordance with applicable laws and regulations.

D. Additional Information:

For more detailed information on how Omicron handles your Personal Information, including our data collection practices, security measures, and third-party disclosures, please refer to our main Privacy Policy available.

Schedule II- Privacy Policy Supplement- Outside the United States

A. Application:

This supplemental section applies to users residing outside the United States and serves as an extension of our Privacy Policy. It contains essential information mandated by the General Data Protection Regulation (GDPR), ensuring transparency in data processing practices. Should you have any queries, please refer to the contact details provided below.

B. Purpose:

This section delineates critical aspects including controllership of Personal Information, legal bases for processing, user rights, data transfer safeguards, and contact information for further inquiries.

C. Controllers of Personal Information:

Controller: For the purposes of the Controller of your Personal Information, Omicron Group Solutions LLC (hereinafter referred to as “Company” or “us” or “we” or “our“) shall be the Controller.

Payments Controller: For payment-related services, various Omicron Payment Gateway Partner(s) are responsible, contingent upon your country of residence.

D. Processing of Payment Information:

To utilize our payment services on the Platform, certain information is required by the Payments Controller to facilitate transactions and adhere to legal requirements, including anti-money laundering regulations. This information encompasses:

●      Payment Information: Your financial details, like bank account or credit card information, are necessary for processing payments and legal compliance.

●      Identity Verification and Other Information: To verify your identity and ensure compliance, the Payments Controller may request identity verification documents (e.g., government-issued ID) and authentication details (e.g., date of birth, address).

How we use your Personal Information:

In the context of payment services, we utilize your Personal Information to:

●      Enable or authorize third parties to use payment services;

●      Detect and prevent money laundering, fraud, and security incidents;

●      Conduct security investigations and risk assessments;

●      Fulfill legal obligations, such as anti-money laundering regulations;

●      Enforce payment terms and other payment policies;

●      Optionally, send promotional messages, marketing materials, and relevant information based on your preferences; and

●      Continuously enhance and optimize payment services for improved user experience.

E. Legal Bases for Processing Personal Information:

●      By Payments Controller: The Payments Controller processes this Personal Information given its legitimate interest in improving the payment services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.

●      By Omicron Platform: We process this Personal Information for the purposes outlined in the Privacy Policy (see Clause 4 and Clause 5) given our legitimate interest in improving Omicron, including developing and improving our Services, and our users’ experience with it, and where it is necessary for the adequate performance of the contract with you.

F. Your Rights:

Under applicable law, you have certain rights that we respect and uphold. While some of these rights are applicable in general, others may apply only in specific circumstances. We may request verification of your identity and request details before taking further action on your inquiries.

●      Access and Portability: You have the right to request access to certain copies of your Personal Information held by us. In certain cases, you may also request copies of the Personal Information you provided to us in a structured, commonly used, and machine-readable format, or ask us to transmit this information to another service provider where technically feasible;

●      Rectification: You can request us to correct any inaccurate or incomplete Personal Information;

●      Erasure: While we generally retain your Personal Information as necessary for contractual performance, legal compliance, and as permitted by law, you have the right to request deletion of your Personal Information, subject to certain limitations and restrictions;

●      Withdrawing Consent: If we process your Personal Information based on your consent, you have the right to withdraw consent at any time. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities performed before its withdrawal;

●      Restriction of Processing: You can limit how we use your Personal Information, especially in cases where you contest its accuracy, oppose erasure, no longer require the information for processing purposes, or have objected to processing pending verification of legitimate grounds; and

●      Objection to Processing: You have the right to object to the processing of your Personal Information based on specific grounds, such as direct marketing, legitimate interests, or public interests. We will cease processing your Personal Information for these purposes unless we have compelling legitimate grounds or where processing is required for legal claims.

G. Operating Globally:

To support our global operations, we and/or payment gateway partners may transfer, store, and process your information within our network of companies, partners, and service providers. It’s important to note that the laws in other countries may differ from those applicable in your country of residence. In certain situations, courts, law enforcement agencies, regulatory bodies, or security authorities in other countries may have the right to access your Personal Information.