This privacy policy sets out how OSO Play uses and protects your personal data through your use of our services and this website.
OSO Play does not sell Personal Data to third parties. We always strive to protect your personal data to the highest level and collect data only to the necessary extent. Consequently, we process personal data solely for the purposes described in this privacy policy. Personal data is not transferred, disclosed, or otherwise made available to third parties in exchange for monetary or other valuable consideration.
1) Important Information and Who We Are
This privacy policy gives you information about how OSO Play collects and uses your personal data through your use of this website.
This website is not intended for people under the age of 18, and we do not knowingly collect data relating to people under the age of 18.
OSO Play, Inc. (a corporation registered under the laws of the State of Delaware, United States of America) (referred to as “OSO Play”, “we”, “us” or “our” in this privacy policy) is the controller and responsible for your personal data.
Your consent is voluntary, and you may withdraw it at any time, subject to applicable laws. Please note, withdrawal of consent may impact your ability to complete the identification process or use our other services. However, processing of your data may still occur in certain instances where it is required by law, to fulfil other legal obligations, or in accordance with our Privacy Policy.
You confirm that all personal data provided by you, including for identification and verification purposes, is true, accurate, and complete.
If you have any questions about this privacy policy, including any requests to exercise your legal rights (Paragraph 9), please contact the us using the information set out in the contact details section (Paragraph 13).
2) The Types of Personal Data We Collect About You
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
Identity Data – includes first name, last name, citizenship / country of origin, date of birth, age, gender, session codes / flight numbers.
Contact Data – includes email address and telephone numbers.
Technical Data – includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, device type, operating system and platform, device ID and other technology on the devices you use to access this website.
Profile Data – includes your username, your interests, preferences, feedback and survey responses.
Usage Data – includes information about how you interact with and use our website, products and services.
Communications Data – includes your communication preferences.
We may also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
3) How Is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
apply for products or services offered by or through us;
use our products or services;
request marketing to be sent to you;
give us feedback or contact us;
use our communication channels.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy www.Oso.ge for further details.
Technical Data is collected from the following parties:
analytics providers such as Google;
advertising networks; and
search information providers.
Contact, Financial and Transaction Data is collected from providers of technical services.
4) How We Use Your Personal Data
Legal Basis:
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
Conclusion or performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example when you enter your personal data on our website.
Public availability of data.
Purposes For Which We Will Use Your Personal Data:
We process your personal data only for specific, clearly defined, and legitimate purposes, and only to the extent necessary for those purposes, including:
to assess your eligibility for and provide our services and products;
to register you as a customer and establish, perform, and manage contractual relationships with you;
to communicate with you, including sending notices, updates, and responding to your requests or complaints;
to ensure the proper functioning, administration, and security of our systems, platform, and business operations;
to ensure the security of personal data and prevent unauthorized access, disclosure, or other unlawful processing;
to fulfil our legal and regulatory obligations;
to prepare statistical data, analytical reports, surveys, and research, aimed at improving our services and customer experience, provided that such processing does not adversely affect your rights and freedoms;
to protect our legitimate interests, legal rights, and property, provided that such interests do not override your fundamental rights and freedoms; and
for marketing purposes, with your consent, to offer and promote products and services and carry out marketing activities.
We will not process your personal data for purposes incompatible with the original purposes of processing, unless we obtain your consent or such processing is otherwise permitted by law.
How We May Use Artificial Intelligence (AI):
To automate operational processes, improve services, and enhance the quality and efficiency of decision-making, we, or our contractors, may use artificial intelligence (AI) technologies / platforms.
In this context, we, or our contractors, may process your personal data, including:
Personal data you have provided to us;
Personal data obtained by us during your use of our services or other interactions with us.
When processing personal data using AI, we ensure compliance with the applicable data protection obligations:
Lawful basis for processing – Personal data is processed only on a lawful basis, determined according to the specific business process.
Principles of data processing – Personal data is shared with AI technologies / platforms only when necessary, proportionate, and relevant for the defined purpose. Only data required to achieve the specific purpose is processed. Where feasible, personal data is anonymized or pseudonymized.
Data security – When using AI technologies/platforms, the security of your personal data is protected. The use of AI is subject to strategic and risk-oriented analysis, which includes evaluating its compliance with security standards and regulatory requirements.
Employee awareness – Employees receive regular and targeted training on the ethical use of AI for the safe, purposeful, and ethical use of AI platforms by our employees.
Companies supplying AI technologies/platforms (Third-party providers) – We use AI platforms only from providers with a strong reputation and which have implemented all necessary measures to comply with data subject rights, data security, and other legal requirements. Additionally, data is processed based on written agreements between us and these companies, in compliance with applicable laws.
Direct Marketing:
You may receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing. We may also analyze your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
Third-Party Marketing:
We do not share your personal data with any third party for their own direct marketing purposes. If we decide to share your personal data for such purpose, we will get your express consent in advance.
Opting Out of Marketing:
You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at our address below.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes (for example relating to confirmations for your successful or unsuccessful verification for a product/service), updates to our Terms and Conditions, checking that your contact details are correct.
Cookies:
For more information about the cookies we use and how to change your cookie preferences, please see our Cookie Policy at: www.Oso.ge
Disclosures of Your Personal Data
We may share your personal data where necessary with the parties set out below for the purposes set out above.
Your legal representatives;
Parties involved in a transaction;
Entities determined by law to fulfil legal obligations;
Service providers, including external auditors, consultants, advisors, courier services, research organizations, and IT service providers (e.g., cloud infrastructure services, automation services) or/and any other persons having the similar functions;
Companies within our group;
Third parties in a business acquisition or restructuring, to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy;
Other third parties with your consent.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We will not transfer your data to third parties if, due to their activities and/or objectives, there is a high risk of inappropriate data processing or violation of your rights.
International Transfers
We may transfer your personal data to service providers in various countries that carry out certain functions on our behalf, if there are grounds outlined in the applicable law.
Whenever we transfer your personal data abroad to service providers, we ensure a similar degree of protection is afforded to it under the applicable law by ensuring that the following safeguards are in place:
We will only transfer your personal data to countries that have been deemed by the relevant local authorities to ensure adequate data protection guarantees (including, without limitation, Germany, where our servers are located).
If we transfer your data to another country, which does not provide adequate data protection guarantees, we will ensure to conclude the data processing agreement, which ensures appropriate safeguards for your data as required under the relevant legislation. We will also obtain permission from the Data Protection Service and/or your consent.
We may use specific standard contractual terms approved for use under the applicable laws which give the transferred personal data the same protection as it has in the jurisdiction of origin. To obtain a copy of these contractual safeguards (if any), please contact us at the contact information set out in this policy.
You expressly acknowledge that OSO Play is registered in the State of Delaware, Unites States of America, and that by sharing your personal data to us, you consent to OSO Play being the controller of your personal data.
Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data Retention
How Long Will We Use Your Personal Data?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we may be required to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a set number of years after they cease being customers, among others, for tax purposes. This includes data retention throughout the service period and as long as necessary after its completion to achieve the specific purpose of the processing.
In some circumstances you can ask us to delete your data: see Paragraph 9 below for further information.
In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your Legal Rights
You have a number of rights under data protection laws in relation to your personal data.
Among others, you have the right to:
Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting Out of Marketing in Paragraph 4 for details of how to object to receiving direct marketing communications).
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
If you want us to establish the data’s accuracy;
Where our use of the data is unlawful, but you do not want us to erase it;
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us.
No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What We May Need from You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Complaints
You have the right to make a complaint to the relevant authorities responsible for personal data protection. However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand.
Changes to the Privacy Policy and Your Duty to Inform Us of Changes
We keep our privacy policy under regular review.
From time to time, without prior notice to you, the text of the privacy policy may be amended or supplemented (including in cases of changes in the applicable legislation). Your continued access and use of our website and our services after such variation constitutes your acceptance of the new edition of the privacy policy. We recommend checking the date and version of the privacy policy upon each use of our website and services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
Third-Party Links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Contact Details
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
Email address: Hello@Oso.ge.
Any changes to the Privacy Policy will be published on our website, along with the update date. Please feel free to contact us for any previous versions of this document.