Thanks for supporting Opnoh. For us to protect your personal data when you enjoy using the services on Opnoh.com, we have developed this privacy policy, which is actually a contract that governs the use of our services. Please note that California residents still specially request the SUPPLEMENTAL PRIVACY NOTICE FOR CALIFORNIA RESIDENTS. A special definition is required for the Opnoh site entities that provide certain limits, more details refer to Terms and Conditions of Opnoh.com The different entities of Opnoh Sites act as a joint controller of personal data together with OPNOH GROUP LLC., CONSULT´EM ENTERPRISE (Collectively, "Opnoh" "We", "Us" or "Our

1.1 Definition of personal data.

Personal data means any information relating to an identified or identifiable natural person ('data subject'); An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data. Personal data does not include data that has been irreversibly anonymized or aggregated in such a way that it can no longer allow us, either in combination with other information or otherwise, to identify you. Below is a description of the types of personal data we may collect and how we may use them:

1.2 What personal data we collect


Depending on the products and services you choose, we collect different types of personal data from you or about you. (a) Data you provide. We collect the personal data that you provide to us when you create an account to use our products and services or interact with us, such as when you fill out account information, contact us, participate in an online survey, use our online help or our online chat tool.

(b) Data from your terminal equipment. Photos / Media / File. Our application may use files or data stored on your device. If you want to prevent our application from accessing your phone data, you can reset your permission on your phone. After obtaining your permission, access to Photos / Media / Files may include the ability to:
① Read the contents of your USB storage (such as an SD card).
② Add content to your USB storage
③ Format external storage
④ Mount or unmount external storage

Local storage.
We may collect and store information (including personal data) locally on your device through mechanisms such as browser web storage (including HTML 5) and application data caches.

Camera.
You can upload photos when commenting through online services. Therefore, we must collect pictures and other information from your device's camera and photos. For example, you will not be able to upload photos from your camera roll unless we can access your camera or photos with your permission.

Unique application numbers.
Certain services include a unique application number. This number and information about your installation (for example, the type of operating system and the version number of the application) may be sent to the website when you install or uninstall that service or when that service periodically contacts our servers, such as for updates. automatic.

(c) Purchase data .
If you make a purchase, we collect personal data related to the purchase. This data includes your purchase information, such as your PayPal email, username, shipping address and other authentication information, as well as billing, shipping and contact information.

(d ) Data on the improvement of our services and products.
When you visit our websites, we may collect data about the type of device you use, the unique identifier of your device, the IP address of your device, your operating system, the type of Internet browser you use. , usage information, diagnostic information, and location information on or about the computers, phones, or other devices on which you install or access our products or services. When available, our services may use GPS, your IP address, and other technologies to determine the approximate location of a device that enables us to improve our products and services.


1.3 How we use your personal data
Generally speaking, we use personal data to provide, improve and develop our products and services, to communicate with you, to offer you specific advertisements and services, and to protect ourselves and our customers

(a) Provide, improve and develop our products and services.
We use your personal data to help us provide, improve and develop our products and services. This may include the use of personal data for purposes such as the entire checkout process, improving the user experience, data analysis, research, and audits. Such processing is based on your express prior consent or our legitimate interest in offering you products and services. We recommend that you read these privacy policy rules carefully before participating. If you no longer wish to accept the above services we provided, please contact us to opt out.

(b) Communicate with you
Subject to your express prior consent, we may use personal data to send you marketing communications in relation to our own products and services, communicate with you about your account or transactions and inform you about our policies and terms. If you no longer wish to receive email communications for direct marketing purposes, please contact us to opt out. We may also use your data to process and respond to your requests when you contact us. If you no longer wish to accept the above services we provided, please contact us to opt out.

(c) Deliver and measure targeted advertisements and services
Subject to your express prior consent, we may use your personal data to personalize your experience with our products and services and on third party websites and applications and to determine the effectiveness of our promotional campaigns. You are free to choose whether to receive promotion information or not. If you no longer wish to accept the above services we provide, please email us to unsubscribe or choose "unsubscribe" to opt out of receiving those emails.

(d) Promotion of security and protection
Subject to your express prior consent, we may use some technological measures to protect your personal data to help verify the accounts and normal user activities, as well as to promote data security, such as monitoring fraud and investigating suspicious or potentially illegal activities or violations of our terms or policies. Such processing is based on our legitimate interest in helping to ensure the security of our products and services.

1.4 How we store your Personal Data.

We may take technological measures to ensure that your personal data record is complete and accurate, such as cookies and technologies Similar. And subject to your express prior consent, we may store our record of processing your personal data for ten years.

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We use cookies and similar technologies to provide, protect and improve our products and services, for example by personalizing content, serving and measuring ads, understanding user behavior and providing a more secure experience. You can delete or reject cookies using your browser or device settings, but in some cases doing so may affect your ability to use our products and services.

2.1 Definition of "cookies"
Cookies are small pieces of text that are used to store information in web browsers. Cookies are widely used to store and receive identifiers and other information on computers, phones, and other devices. These types of files perform a number of different functions, such as remembering your preferences. and selected items, helping you improve your site experience and trying to make sure that the ads or offers you see online are more relevant to you. These "cookies" can be divided into 4 types, each of which is described below.

2.2 Types of cookies
(a) Strictly necessary cookies. To provide you with the essential services of our website, such as visiting our website or making a purchase, these cookies are essential. If you disable these cookies, we will not be able to fulfill your request.

(b) Performance cookies.
This type collects anonymous information about how people use the site and the data is merged with other users to allow us to improve the operation of the site. For example, we use Google Analytics cookies to help us understand how customers get to our site, navigate or use our site, and highlight areas where we can improve areas such as navigation, shopping experience, and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established. If you disable or decline these cookies, you may not be able to use certain features of our websites and services, and it may reduce the support or information we can provide you.

(c) Functionality cookies.
These cookies can remember operations as your preference so that we can provide you with better services and improve our operation models. If you reject these cookies, you may not be able to use certain functions on our websites.

(d) Targeting cookies or advertising cookies.
These cookies collect information about your browsing habits so that advertising is more personalized for you. These cookies can remember the websites you have visited and share them with third parties, such as advertisers. If you reject these cookies, you may not be able to do so. use certain features of our websites and services, and it may affect your experience.

(e) Social media cookies.
These cookies are used to allow you to share pages and content on our websites and services through third-party social networks and others. websites. These cookies can also be used for advertising purposes. If you reject these cookies, you may not be able to use certain functions of our websites and this may affect your experience.

2 .3 Cookies placed by third parties
You may also find cookies on our websites that are placed by third parties. For example, when you buy our products online, our e-commerce provider may use cookies and other technologies. We may also allow third parties to place cookies on our websites to track information about your online activities and / or on third-party online sites or services, including to send you targeted advertisements based on that information, which may include remarketing of our products and services that you have seen on our websites and third party websites.
This Cookie Statement does not apply to cookies, applications, technologies or websites that are owned and / or operated by third parties, or the practices of such third parties, even if they use or access our technology. to store or collect information. To understand how third parties use cookies, review their privacy policies.

2 .4 Control and exclusion of cookies
You can change your browser settings to prevent cookies from being stored on your computer or mobile device without your explicit consent. The "help" section of your browser will normally provide details on how to manage cookie settings. If you choose to decline cookies, as stated above, you may not be able to use certain features of our websites and services.

2 .5 Other similar technologies
DPAPI (Data Protection Application Programming Interface) is a simple cryptographic application programming interface available as an integrated component in Windows 2000 and later versions of Microsoft Windows operating systems. In theory, the Data Protection API can allow symmetric encryption of any type of data; In practice, its main use in the Windows operating system is to perform symmetric encryption of asymmetric private keys, using a user or system secret as a significant entropy contribution. DPAPI can help to record and store the personal data of users. Data Cube is a simple application to record and analyze personal data. If you choose to decline cookies, as stated above, you may not be able to use certain features of our websites and services.

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We take reasonable steps to ensure that your personal data is accurate, complete, and up-to-date.
3.1 In accordance with the protection of your privacy, you have the following rights:


(a) You have the right to contact us to find out whether or not your personal data is being processed and, if so, to access the information and personal data, including but not limited to the purposes of the processing and the categories of personal data in question.

(b) You have the right to contact us to correct or delete your related inaccurate personal data. Taking into account the purposes of the processing, you are also free to complete incomplete personal data, including by supplying a supplementary declaration.

(c) You have the right to obtain from us the erasure of personal data concerning you.

(d) You have the right to contact us to establish the restriction of processing, which limited our processing authorities.

(e) You have the right to receive the personal data you provide in a structured, commonly used and machine-readable format and to transmit that data to a third party. (f) You have the right to contact us to present your objection for reasons related to your particular situation, at any time to the processing of personal data.

(g) You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects on you or similarly significantly affects you. When you need to realize this right, please contact us to offer assistance.

To protect the privacy and security of your personal data, we may request data that allows us to confirm your identity and right to access such data, as well as to search and provide you with the personal data that we maintain. There are instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal data that we maintain.

You can contact us to exercise your rights. We will respond to your request within 30 days.


3. 2 Verification of your data

(a) How can I verify my personal data?
You can verify your personal data by entering "My account".

(b) Deletion of your information
Please contact us when you think it is necessary to delete your information: Personal data to provide, improve and develop our products and services. If this type of data is deleted, your account will be close to being deleted because your account cannot be used normally without this type of data.
Personal data that we use to communicate with you. If this type of data is deleted, we will not be able to contact you. Please make your decisions with caution.
Personal data to offer and measure specific advertisements and services. If this type of data is deleted, you will not receive the latest marketing news and personalized shopping services.

Personal data related to the promotion of security and protection. If this type of data is deleted, your account will be severely threatened that you cannot use your account normally.


If you delete your data, we have no obligation to retain your data and we may delete some or all of your data without liability. However, we may retain data related to you if we believe it may be necessary to prevent future fraud or abuse, if required by law, or for legitimate purposes such as non-personal data analysis, account recovery, auditing our records and enforcing our rights and obligations under our agreements

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Please confirm that when you agree to this privacy statement, your age is at least 16 years old or you have the authorization of a guardian. Please contact us immediately if you become aware that a child under the age of 16 has provided us with personal data.

We make certain personal data available to strategic partners who work with us to provide our products and services or to help us market to customers. We will only share personal data with these companies to provide or improve our products, services and advertising; It will not be shared with third parties for their own marketing purposes without your express prior consent.

5.1 Service providers
We share personal data with companies that provide services on our behalf, such as website hosting, email services, marketing, sponsoring sweepstakes, contests and other promotions, auditing, fulfilling customer orders, analyzing data, providing customer service, and conducting customer satisfaction surveys and research. These companies are required to protect your data and may be located anywhere we operate.


5.2 Corporate affiliates and corporate business transactions
We may share personal data with affiliated companies and business partners. In the event of a merger, reorganization, acquisition, joint venture, assignment, spin-off, transfer or sale or disposal of all or part of our business, including in connection with any bankruptcy or similar proceedings, we may transfer any and all personal data to the corresponding third party.


5.3 Legal compliance and security

It may be necessary (by law, legal process, litigation and / or requests from authorities and government within or outside your country of residence) that we disclose personal data. We may also disclose personal data if we determine that, for purposes of national security, law enforcement, or other matters of public importance, the disclosure is necessary or appropriate. We may also disclose personal data if we determine in good faith that disclosure is reasonably necessary to protect our rights and seek available remedies, enforce our terms and conditions, investigate fraud, or protect our operations or users.


5.4 Legal basis for the processing of personal data of EEA residents
It may be necessary (by law, legal process, litigation and / or requests from authorities and governments inside or outside your country of residence) that we disclose personal data. We may also disclose personal data if we determine that, for purposes of national security, law enforcement, or other matters of public importance, the disclosure is necessary or appropriate.

If you reside within the European Economic Area (EEA), our processing of your personal data will be justified if one of the following conditions is met:

(a) Always that we obtain your consent;
(b) Whenever the processing of your personal data is necessary for the performance of a contract between you and us or to take pre-contractual measures when requested;
(c) When the processing is necessary for us to comply with a legal obligation;
(d) When the processing is necessary for the purposes of our legitimate interests;
(e) When the processing is necessary for legal and reasonable reasons (in this situation, we will specifically explain the details)

The definition of Processing is any operation or set of operations that is carried out on personal data or on sets of personal data, whether by automated means or not, such as collection, registration, organization, structuring, storage, adaptation or alteration, retrieval, consultation. , use, disclosure by transmission, diffusion or making available, alignment or combination, restriction, erasure or destruction.

We offer products and services to customers around the world and your personal data may be transferred to and stored at a destination outside the European Economic Area ("EEA"). It may also be processed outside of the EEA by personnel working for Opnoh or one of our suppliers. Data protection laws vary between countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy. We also sufficiently consider certain legal frameworks related to data processing.

When we provide products and services to customers with the help of our affiliates, business partners and service providers, your personal data may be processed outside the EEA. In such circumstances, we will enter into model contractual clauses or rely on alternative legal bases such as the Privacy Shield, where applicable, or binding corporate rules that our partners or service providers have adopted. Appropriate or adequate safeguards, for example encryption technology, will be provided to ensure the security of your information. Our clients have the right to obtain a copy of this data transferred to a third country. If you need to assert your rights, please contact us. Regarding the details of the data processing of third parties that may reach your personal data, please read the following introduction from Third Parties.

7.1 Prior authorization from third parties to us
(a) Facebook, Instagram Twitter, Google, VK. When you log in with your account via Facebook, Instagram, Twitter, Google, VK on Opnoh.com, we are available to obtain your login information automatically because these third parties have previously authorized us to collect your information to help you conveniently log in.
To better protect your information, we sincerely recommend that you familiarize yourself with the privacy policy provided by these third parties before logging in through your registered account on their websites. Consequently, keep in mind that you also need to take steps to protect yourself, especially online. Do not share your password with anyone else. Also remember to leave the website and close your browser window when you have finished your work. If you really care to provide us with your personal data through prior authorization, you can register a new account with Opnoh.

(b) Payu , PayuBiz . If you choose to pay online via "Pay with" Payu , PayuBiz ", please note the fact that once you click the button, you will be linked to the site Payu , PayuBiz website. The personal data that you are asked to provide, including your card number, your billing address and your contact information, will be collected and processed by Payu , PayuBiz instead of Opnoh, although our trademark / logo can still be seen in the upper left corner. website. We sincerely recommend that you know the policy of privacy of Payu, PayuBiz
and that you choose carefully between the different payments. Opnoh should not be responsible for the data processing by Payu, PayuBiz when you click on the button "Pay with Payu, PayuBiz".

7.2 Other third parties that may access your information
To provide better products and services to our customers, we may transfer ering your data mainly to the two types of third parties, Third parties related to advertising and marketing: Google, Facebook, Instagram, Twitter, Amazon, Pinterest, TradeTracker, etc. Information about your activities on our website, for example what products you like to browse, may be transferred to these third parties. You may receive communication letters about advertising and marketing in your email from us and / or selected third parties. You have the option to opt out of receiving marketing communications from us and / or selected third parties. When you no longer wish to receive advertisements from us and / or selected third parties , you must opt ​​out by contacting us (email) or by clicking the "unsubscribe" link in any email communication you receive.

Third parties related to Payment and Delivery —— Stripe, 2Checkout, Payu, PayuBiz, Razorpay, etc.
If you make a purchase with us, your payment and delivery information will be necessary for the trade. Your information may be transferred to third parties and processed by them. We promise that appropriate or adequate safeguards, for example encryption technology, will be provided to ensure the security of your information. This type of personal date is so important to your purchasing activities that we strongly recommend that you think twice when you want to delete or object to the processing of this data.

7.3 About a third party located in a third country
As we have indicated above, the model contractual clauses or alternative legal bases or corporate rules Binding documents will help protect the security of your information.Once we notice that a third party breaches their obligation and violates your privacy, we will immediately notice it to correct your error. If you notice that a third party breaches their obligation and violates your privacy due to an error from Opnoh, you can contact us for solutions. We promise that appropriate or adequate safeguards, for example encryption technology, will be provided to ensure the security of your information. Our clients have the right to obtain a copy of this data transferred to a third country. If you need to assert your rights, please contact us.

7.4 About third party websites
Our website may contain links to and from the websites of our partner networks, advertisers and other third parties. If you follow a link to any of these websites, please note that they have their own privacy policies and we do not share your information with them unless your permission or other legal basis authorizes us to do so. Please review these policies before submitting personal data to these websites. We should not be responsible for the personal data breach caused by these third party websites.

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We use reasonable technical, administrative and physical security measures designed to safeguard and help prevent unauthorized access to your data and to properly use the data we collect. < br /> For example, access to your personal data is strictly limited to our data controller, data processor, data protection officer who need access to such data to perform their assigned job duties. We have created a recovery system to prevent the destruction, loss, alteration or unauthorized disclosure of your data due to automated technology. It is important that you take precautions to protect against unauthorized access to your account credentials, computer, or other devices. "Breach of personal data" means a breach of security that leads to the destruction, loss, alteration, unauthorized disclosure or access to personal data transmitted, stored or otherwise processed, accidentally or illegally. If you notice this type of personal data breach, please contact us immediately. We will investigate any complaints and notify the individual of the outcome of the investigation within a reasonable period of time. Opnoh has created a Data Protection Officer (DPO) to provide professional analysis on the processing of personal data. Whenever you need help directly from our DPO, you can inform us of your request. Please note that despite our best efforts, no security system is impenetrable.

From time to time, we may update our Privacy Policy to reflect new or different privacy practices. We will notify our customers when we make substantial changes to the Privacy Policy. The modification of the Privacy Policy is of great importance to guarantee your rights over personal data. Accordingly, we sincerely recommend that you consult the Privacy Policy available online periodically. In addition, you can always consult the Privacy Policy through quick links whenever you need to enter your personal data. Simultaneously, we will notify you of the modification by sending a notice to your account. There will be a special quick link in your account to provide the full text of the Privacy Policy.

If you have any questions, please click here to contact us. < / p>

SUPPLEMENTAL PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental Privacy Notice is in addition to the information in our Privacy Policy and applies only to California residents.

Summary of information collected and examples of uses
California law requires that we disclose information regarding the categories of personal information we have collected about California consumers, the categories of sources from which the information was collected, the business or commercial purposes (as defined by those terms in applicable law) for which the information was collected, and the categories of parties with whom we share personal information.

Categories of personal information collected . The personal information that we collect from, or have received from you:

• You identify yourself such as your name, aliases, address, telephone numbers or IP address;
• Personal information, such as a credit card number;
• age, gender or other protected classifications, for example, if you create a child profile or a baby registry;
• Commercial information, such as the purchase and content transmission activity;
• Financial data, such as payment method or financial account information;
• Internet or other electronic network activity information, including content interaction information, such as content downloads, streams, and playback details;
• Geo location data, such as the location of your device or computer;
• Visual information, such as images and videos collected or stored in connection with our services;
• Data reference, such as information about your purchasing preferences.


For commercial or commercial purposes .
We or our service providers collect the above categories of information for the following commercial or commercial purposes:

• Our or our service provider's operational purposes;
• Audit consumer interactions on our site (for example, measure ad impressions);
• Detect, protect and prosecute fraudulent or illegal security incidents and activities;
• Error detection and error notification;
• Personalize the content that we or our service providers display on the Services (for example, contextual advertisements);
• Provide the Services (for example, account service and maintenance, order processing and fulfillment, customer service, advertising and marketing, analytics and communication about the Services);
• Improve our existing Services and develop new services (for example, by conducting research to develop new products or features);
• Other uses that advance our commercial or economic interests, such as third-party advertising and communication with you about relevant offers from external partners;
• Other uses about which we notify you.

Categories of information sources that we collect.

< br /> • Individuals / You
• Your use of our services / automatic collection
• Agents / service providers
• Affiliates
• Third parties
• Other users ( for example, when another user sends you an item as a gift)

Categories of third parties that we may share information with .

• Service providers / Agents

• Affiliates

• Third parties

• Other users (where you publicly disclose the information)

Rights If you are a California resident, you may have certain rights.California law may allow you to request that:

• Provide you with the categories of personal information that we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we share personal information
• Provide access to and / or a copy of certain information we hold about you.

• Delete certain information we have about you.
• Stop using personal information: In the twelve months prior to the effective date of this description, you have not sold any personal information of the consumers, as these terms are defined in the California Consumer Privacy Act.

You may have the right to receive information about the financial incentives that we offer you. You also have the right not to be discriminated against (as provided in applicable law) for exercising some of your rights. Certain information may be exempt from such requests under applicable law. We need certain types of information in order to provide the Services to you. If you ask us to remove it, you may no longer be able to access or use the Services.

For more information on how to access, review and correct your account information; opt out of certain marketing, advertising, location gathering, and cookie campaigns; and deactivate your account, see other sections of this Privacy Policy. If you wish to exercise any of your rights as a California consumer, please send a request to data@opnoh.com or Customer Service.

We take the privacy of your personal information very seriously and want to ensure that we only provide your personal information to you and your authorized agent. The CCPA also requires that we verify the identity of each person who makes a request to find out what personal information we hold about you or to delete the personal information we hold about you. Therefore, you will be asked to verify your identity before we can fulfill your request. To do so, you will typically need to demonstrate control of the appropriate account and show your California residency. You can also designate an authorized agent to make a request on your behalf. To do this, you must provide us with a written authorization or power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.


28-Oct.-2021

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