Privacy Policy

Effective Date: March 9, 2020

1. Purpose

This Privacy Policy is incorporated by reference into the Operam Terms of Service (the “Terms”). The terms “Operam”, “we” and “us” include Operam Inc. and our affiliates and subsidiaries. This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt-out of a use or correct or change such information. All other terms not defined in Section 14 or otherwise herein will have the meanings set forth in the Terms.

2. Scope

This Privacy Policy applies to Personal Information (“Data”) that is Processed by Operam in the course of our business, including on the website (“Site”), blogs, and through our Operam technology solutions that we provide to advertisers, publishers and other businesses (the “Services”). All individuals whose responsibilities include the Processing of Personal Information on behalf of Operam are expected to protect that data by adherence to this Privacy Policy. This Privacy Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions. The gathering of information is always reasonable in relation to our business or the purpose for which the Services exist, and includes, without limitation, various information provided by you or your internet service provider (whether mobile data or otherwise, an “ISP”) to us. We in turn, gather information from, and share information with necessary parties with whom or which we have an ongoing business relationship or may need to come into possession of user information in order to enable, facilitate, or otherwise enhance your experience with the Services. We take each user’s data privacy seriously, and at all times endeavor to collect, compile, handle, store, and disseminate user data (whether or not Personal Information as defined below, “Data”) in compliance with applicable law, including, as may be applicable to certain users, under either the 2018 California Consumer Privacy Act (the “CCPA”), or the European Union General Data Protection Regulation (the “GDPR”).This Privacy Policy sets forth the manner by which we undertake due care with respect to: (i) protecting Data in accordance with applicable law and practices which we deem proper and commercially reasonably in relation to each form of Data, (ii) protecting the rights of various parties handling, providing, and sharing or receiving Data, such as users, our employees and contractors, and our business partners, (iii) our transparency with respect to the processing, handling, storage, and dissemination of Data, (iv) our measures in respect to protection from data breach and other unauthorized disseminations of Data, and (v) applicable law (including with respect to the CCPA and GDPR, as applicable).

3. Transparency/Notice—Types of Personal Information We Collect and How We Use It

“Personal Information” has varying definitions depending on the laws applicable to you. The Services are controlled and provided from within the Unites States, however, Company complies with laws and regulations such as the CCPA and GDPR, which each mandate certain definitions of Personal Information.

In regard to more specific definitions, (i) under the CCPA (California Civil Code § 1798.140(o)(1)), Personal Information is considered to be information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, and (ii) under the GDPR is considered to be Data which can be used to directly or indirectly identify the applicable user.

As used herein, Personal Information, includes, without limitation, information such as (i) contact data, including, your first and last name, driver’s license number, biometric information, user name or alias, physical street address, city, state, zip code, phone number and email address, (ii) financial data (such as your bank account number, credit card number, credit card expiration date, and credit card verification code), (iii) demographic data (such as your zip code and gender), and (iv) other legal data (such as your social security number and other sensitive information) or any number of attributes, which taken together may identify you or enable you to be directly identified (such as physical, physiological, genetic, mental, economic, cultural or social characteristics).

Although an Internet Protocol (IP) address can only be used to determine the location of your device within a large radius (on the scale of miles or kilometers), Personal Information, for the purpose of the CCPA and GDPR also includes your IP address, and moreover, certain cookies in relation to your use of the Services.

Notwithstanding the fact that we may treat certain Data as Data which is not Personal Information, and cannot be used in order to identify a user (“Non-Personally-Identifiable Data”), to the extent that the CCPA or GDPR applies to you, we will always treat information based upon such applicable law’s characterization of Personal Information. For example, the IP or cookies of a user within the United States and outside of California may be treated as Non-Personally-Identifiable Data, while the same attribute may be treated by the CCPA and GDPR as Personal Information.

Please note, under the CCPA, public information, aggregate consumer information, and de-identified consumer information are not deemed to be Personal Information. Public information is any information accessible by public records, including as may be obtained by specific request (such as a Freedom of Information Act request). Aggregate consumer information is information which is not specific to your identity, but which may indicate your behaviors and preferences based on statistical comparisons and analytics.

The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with

Operam and the requirements of applicable law. Some of the ways that Operam may collect Personal Information include:

You may provide Personal Information directly to Operam through interacting with the Services, participating in surveys, and requesting Services, or information.

As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.

We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.

3.1 Types of Personal Information We Collect

Operam collects Personal Information regarding its current, prospective, and former clients,customers,users,visitors,guests,andEmployees(collectively“Individuals”). You can use certain aspects of the Services without giving away any Personal Information except for your IP address and certain other data provided by your ISP or device. We may use analytics tools and various cookies in order to improve and analyze the use of our Services. The information collected by these analytics tools is mostly anonymous traffic data including browser information, device information, language. We do not collect additional information, such as your age, gender, interests, clickstream, or anything associated with a so-called user “Internet passport.”

Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an Account with Operam, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:

Communications with Us. We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Services, register for Operam’s newsletter or a loyalty program that we may offer from time to time, request to receive customer or technical support, or otherwise communicate with us.

Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Sites and/or services and in any manner consistent with the policies provided herein.

Posting on the Site. Operam may offer publicly accessible fan pages, blogs, private messages, or community forums. You should be aware that, when you disclose information about yourself on Operam’s fan pages, blogs, private messages, and community forums, the Site will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.

Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo- location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.

Information Submitted Via Services. You agree that Operam is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. Operam will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.

Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, if you access our Services through a Third- Party application, such as an App Store or SNS, we may collect information about you from that Third-Party application that you have made public via your privacy settings. Information we collect through App Stores or SNS accounts may include your name, your SNS user identification number, your SNS user name, location, sex, birth date, email, profile picture, and your contacts on the SNS. This supplemental information allows us to verify information that you have provided to Operam and to enhance our ability to provide you with information about our business, products, and Services.

The following chart summarizes the type and character of Data we collect, and gives certain examples of Data which we do not collect.

Type of Data

Some Examples of This Type of Data

Do We Collect This Type


A real name, Internet Protocol address, email address, or other similar identifiers.

We may collect this type of Data, and will collect certain Data provided by your ISP when you use the Services.

Personal Information enumerated in the CCPA Customer Records statute

See Section 3 for examples..

We may collect this type of Data

Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

We will only collect this type of Data to the extent you specifically provide it to us.

Commercial information and purchase history data

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

We may collect this type of Data, but only in connection with your use of the Services.

Biometric data

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

We do not presently collect any biometric data.

Internet or other similar network activity data

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

We may collect this type of Data

Geolocation data.

Physical location or movements.

We may collect this type of Data

Device sensory data

Audio, electronic, visual, thermal, olfactory, or similar information.

We may collect this type of Data

Professional or employment-history

Current or past job history or performance evaluations.

We will only collect this type of Data to the extent you

and other information

specifically provide it to us.

Collated Data and inferred or interpolated Data

User preference and habit profile data

We may collect this type of Data

3.2 How Operam Uses Your Information

We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:

To Provide Products, Services, or Information Requested. Operam may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:

Generally manage Individual information and Accounts;
Respond to questions, comments, and other requests;
Provide access to certain areas, functionalities, and features of Operam’s Services; Contact you to answer requests for customer support or technical support;
Allow you to register for events.
Information We Process on Behalf of Our Customers

Our customers may choose to use our Services to process certain data on their own websites or services, which may contain Personal Information. The data that we Process through our Services is processed by us purely on behalf of our customer, and our privacy practices will be governed by the contracts that we have in place with our customers, not this Privacy Policy.

If you have any questions or concerns about how such data is handled or would like to exercise your rights, you should contact the person or entity (i.e., the data controller) who has contracted with us to use the Service to Process this data. Our customers control the Personal Information in these cases and determine the security settings within the account, its access controls and credentials. We will, however, provide assistance to our customers to address any concerns you may have, in accordance with the terms of our contract with them.

Administrative Purposes. Operam may use Personal Information about you for its administrative purposes, including to:

Measure interest in Operam’s Services;

Develop new products and Services;

Ensure internal quality control;

Verify Individual identity;

Communicate about Individual Accounts and activities on Operam’s Services and systems, and, in Operam’s discretion, changes to any Operam policy;

Send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance;

Process payment for products or services purchased; Process applications and transactions;
Prevent potentially prohibited or illegal activities; Enforce our terms.

Marketing Operam Products and Services. Operam may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Operam may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:

To tailor content, advertisements, and offers;

To notify you about offers, products, and services that may be of interest to you;

To provide Services to you and our sponsors;

For other purposes disclosed at the time that Individuals provide Personal Information; or

Otherwise with your consent. You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 6 below.

Research and Development. Operam may use Personal Information to create non- identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Operam may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will

be used along with that of other study participants. We may share non-identifiable or aggregated data for research and analysis purposes.

Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Operam’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 6 below.

Services via Mobile Devices. From time to time, Operam may provide Services that are specifically designed to be compatible and used on mobile devices. Operam will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Mobile versions of Operam’s Services may require that users log in with an Account. In such cases, information about use of mobile versions of the Services may be associated with Accounts. In addition, Operam may enable Individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to Operam to enable Individuals to access Accounts and to enable Operam to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. Operam may use personal or non-identifiable information transmitted to Operam to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices Operam provides.

Aggregated Information Use. Operam may use Personal Information and other information about you to create aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Operam’s Services, or other analyses we create. Aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Aggregated information is not Personal Information, and Operam may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Operam and with Third Parties for our or their purposes in an aggregated form that is designed to prevent anyone from identifying you.

Sharing Content with Friends or Colleagues. Operam’s Services may offer various tools and functionalities. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request.

Other Uses. Operam may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or

any other purpose disclosed to you at the time you provide Personal Information or with your consent.

3.3 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising

We, as well as Third Parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices.

Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.

Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

Social Media Widgets: Our Site includes social media features such as Facebook, Snapchat and Google (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third Party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.

Analytics. We may also use Google Analytics and Fullstory to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop Site content. For more information about Google Analytics, please You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to For information about Fullstory, please visit You can opt out of Fullstory by going to

Our uses of such Technologies fall into the following general categories:

Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our sites, services, applications, and tools. This includes technologies that allow you access to our sites, services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping- carts, saved search, or similar functions;

Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our Site, applications, Services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our Site content, applications, Services, or tools;

Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools. This may include identifying you when you sign into our sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites;

Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

If you would like to change your preferences or opt-out of the Technologies we employ on our Site, Services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

3.4 Third-Party Websites, Social Media Platforms, and Software Development Kits

The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Operam does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

Operam’s Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.

4. Human Resources Data

Operam collects Personal Information from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals.

We acquire, hold, use and Process Human Resources Data for a variety of business purposes including:

Workflow management, including assigning, managing and administering projects; Human Resources administration and communication;
Payroll and the provision of benefits;

Compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;

Job grading activities;
Performance and employee development management; Organizational development and succession planning;
Benefits and personnel administration;
Absence management;
Helpdesk and IT support services;
Regulatory compliance;
Internal and/or external or governmental compliance investigations; Internal or external audits;
Litigation evaluation, prosecution, and defense;
Diversity and inclusion initiatives;
Restructuring and relocation;

Emergency contacts and services;
Employee safety;
Compliance with statutory requirements;
Processing of Employee expenses and travel charges; and Acquisitions, divestitures, and integrations.

5. Onward Transfer—Operam May Disclose Your Information
5.1 Information We Share

We may share your information as described in this Privacy Policy (e.g., with our Third- Party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission.

We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site. Operam has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.

Business Partners. Operam may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. Operam may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Operam. Operam requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Operam provided them.

Displaying to Other Users. The content you post to the Site may be displayed on the Site. Other users of the Site may be able to see some information about you, such as your name if you submit a review. We are not responsible for privacy practices of the other users who will view and use the posted information.

Marketing — Interest-Based Advertising and Third Party Marketing. Through our Services, Operam may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use

this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Operam related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third- Party advertising partners, you may opt-out of such sharing at no cost by following the instructions in Section 6 below.

Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, ours or others’ rights, property, or safety; (iv) to enforce Operam policies or contracts; (v) to collect amounts owed to Operam; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.In addition, from time to time, server logs may be reviewed for security purposes — e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, Operam will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.

We may disclose your Personal Information to a third party for a business purpose or sell certain aspects of your Personal Information, subject to your right to opt-out of those sales (as described herein). When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. The CCPA generally prohibits third parties who permissibly purchase Personal Information from us from further selling or transferring such purchased Personal Information unless you have received an additional express notice of such proposed transfer and an opportunity to opt-out of such transfer and further transfer. In the preceding twelve (12) months from the last update to this Privacy Policy, we have not (i) disclosed Personal Information for a business purpose, or (ii) sold Personal Information.

5.2 Data Transfers

All Personal Information collected via or by Operam may be stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Operam, you consent to the storage of your Personal Information in these locations.

6. Opt-Out (Right To Restrict Processing)
6.1 General

You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Operam’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt-out to further Processing by contacting us as described below. In each case, please make clear in your email what you are opting-out from. We will try to comply with your request(s) as soon as reasonably practicable. Even if you opt-out, we may still collect and use non- Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements. Further note that, if you opt-out in any respect, we will not be able to remove your Personal Information from the databases of third parties with which we have already shared your Personal Information as of the date that we implement your opt-out request. Please note that you may still receive information from third parties to whom we have disclosed your information prior to the time you opted-out. You should contact each party in the event that you no longer want to receive information from such party. Please also note that, if you do opt-out from receiving marketing-related messages from us, we may still send administrative messages to you; you cannot opt-out from receiving administrative messages.

6.2 Email and Telephone Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction- related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding Operam and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.

6.3 Mobile devices

Operam may occasionally send you push notifications through our mobile applications with notices or alerts that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device.

Operam may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device. If you do not want to receive marketing-related SMS text messages from us and our affiliates on a going-forward basis, you may opt-out from receiving such messages by texting back “STOP” or by emailing us at

6.4 Human Resources Data

With regard to Personal Information that Operam receives in connection with the employment relationship, Operam will use such Personal Information only for employment-related purposes as more fully described above. If Operam intends to use this Personal Information for any other purpose, Operam will notify the Individual and provide an opportunity to opt-out of such uses.

6.5 Sharing with Unaffiliated Parties

You may opt-out from our sharing of your Personal Information with unaffiliated third parties for their marketing purposes: If you prefer that we not share your Personal Information on a going-forward basis with unaffiliated third parties for their marketing purposes, you may opt-out from such sharing by emailing us at

6.6 “Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

6.7 Cookies and Interest-Based Advertising

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at, or and You can also choose not to be included in Google Analytics here.

To be clear, whether you are using our opt-out or an online industry opt-out, these cookie- based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will

not be effective on your mobile device. You must separately opt-out on each device. Advertisements on Third-Party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners’ use of this information for interest-based advertising purposes.

6.8 Removal, Deletion, or Correction Requests

If you would like to review, correct, update, suppress, delete or otherwise limit our use of your Personal Information that you have previously provided to us or content you have previously posted on the Services, you may contact us by emailing us at In your request, please make clear what Personal Information or posted content you would like to have changed or removed and what limitations (if any) you would like to place on our use of your Personal Information. We will try to comply with your request as soon as reasonably practicable. Please note that such request does not ensure the complete or comprehensive removal of Personal Information or content posted on the Services. For example, we may need to retain certain information or content for recordkeeping purposes, and there may also be residual information or content that will remain within our databases and other records that will not be removed. We are also not responsible for changing, removing or suppressing information or content from the databases of third parties with which we have already shared your Personal Information or content.

The CCPA provides California residents with specific rights regarding their Personal Information. This Section 6.8 applies only to California residents or other persons who are afforded the rights and protections of the CCPA.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verified request in compliance with the CCPA, we will provide a report to you which sets forth the following with respect to you: (i) categories of Personal Information collected (ii) sources for such collection, (iii) our business or other commercial purpose for selling any such Personal Information, (iv) categories other third parties with which we have shared your Personal Information, (v) the specific scope of any information shared to those third parties, and (vi) if we have sold or transferred your Personal Information, separate lists which set forth (1) each sale, with the categories transferred to each purchaser, and (2) each business-related transaction, with the categories used in connection therewith.

Deletion Request Rights

You have the right to request that we delete any of your Personal Information in our possession and collected from the Services, subject to certain limitations or exceptions. Once we

receive and confirm your verified request in compliance with the CCPA, we will delete your Personal Information from our records, unless a limitation or exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: (i) complete a transaction for which we collected such Personal Information, provide a good or service that you requested and do not wish to terminate or rescind, or otherwise carry out any obligations which are or may become necessary to consummate any obligations to you or requests by you, (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities, (iii) maintain, repair, or improve the Services, including the correction of errors that impair existing intended functionality, (iv) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law, (v) comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.), (vi) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent, (vii) facilitate any lawful internal use or review in connection with our internal processes, or (viii) comply with any law, regulation, order of governmental authority, or other legal process.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verified request in compliance with the CCPA. You may make such a request on your own behalf, on your minor child’s behalf, or on behalf of any entity for which you are a duly appointed representative listed on the California Secretary of State’s website. You may only make such a request for access or data portability twice within a 12-month period with respect to any specific user. Please provide us sufficient information to verify user with respect to whom the request relates, and that you have authority on behalf of such user. Always describe your request with sufficient detail to enable our understanding, response, and implementation.

Response Timing and Format

We make commercially reasonable efforts to respond to a verified request in compliance with the CCPA within forty-five (45) days of receipt of each request. We will inform you as soon as practicable if we believe we require more to evaluate or undertake your requested actions. We will deliver our written response by mail or electronically, at your option, at the contact

information you provide with your request. Any disclosures we provide will only cover the 12-month period preceding our receipt of the verified request in compliance with the CCPA. If we are unable to comply in part or in full, we will provide our reason with the reply to a request. With respect to any data portability request, we will select data formats in our reasonable discretion. We reserve the right to charge a reasonable fee to you for our cost and administrative expense in connection with any request under the CCPA, if your exercise of right is excessive, repetitive, patently unreasonable or without basis, or is otherwise intended to harass, pester, or hinder us or our Services. We will notify you of any fees with our response to a request under the CCPA.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). We do not sell the Personal Information of consumers whom we actually know are younger than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer or parent or guardian of a consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to Personal Information sales may opt- out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by email at the address below. Once you make an opt- out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back in to Personal Information sales at any time by visiting our website and sending us a message. We will only use Personal Information provided in an opt-out request to review and comply with the request.


In making the Services available, we will not discriminate against you for exercising any of your rights under the CCPA. Subject to exclusions under the CCPA, we will not as a result of your exercise of rights under the CCPA (i) deny you goods or services generally available through the Services, (ii) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, (iii) provide you a lesser level or quality of goods or services, or (iv) imply or suggest that you may receive a different price or rate for goods or services, or a different level or quality of goods or services. Notwithstanding the foregoing, we may offer you certain financial incentives permitted by the CCPA which proximally or actually result in different prices,

rates, or quality levels. Any such financial incentive will reasonably relate to the value of the Personal Information to which it relates, provide a disclosure of material terms, and provide an opt-in, which may be revoked at any time.

7. Rights of Access, Rectification, Erasure, and Restriction

In addition to the rights described in Section 6.8 specific to the CCPA, regardless of if the CCPA applies to you, you may inquire as to whether Operam is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may send an e-mail as described below or use any of the methods set out in this Privacy Policy to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by Operam. Please include your full name, email address associated with your Account, and a detailed description of your data request. Such requests will be processed in line with local laws.

Although Operam makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Operam is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Operam determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Operam will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

8. Data Retention

Operam retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services, and, even after you cease use of the Services, for so long as Operam reasonably deems necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. Any data governed by the GDPR that is no longer needed for the purposes specified herein will be deleted.

9. Security of Your Information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure,

and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.

You should feel confident using our Services. However, no system can be completely secure. Although we take very significant steps to secure your information, there is always a chance that your information will not always remain secure, or our computers or systems are illegally accessed, and the data on them stolen or altered. You should always take great care in handling and disclosing your Personal Information. For example, avoid sending Personal Information through insecure email.

Please refer to the Federal Trade Commission’s Services at for information about how to protect yourself against identity theft. We assume no liability or responsibility to you or to any third party arising out of any loss, misuse, destruction, or alteration of your information.

10. Non-US Users

By using the Site, Operam will transfer data to the United States and other jurisdictions around the world. By choosing to visit the Site, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of California and the adjudication of any disputes arising in connection with Operam or the Site will be in accordance with the Terms.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to the Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.

11. Children’s Privacy

The Services are not directed to children under 13 (and in certain jurisdictions under the age of 16) years of age (“Children”), and Operam does not knowingly collect Personally Information from Children. If we learn that we have collected any Personal Information from Children, we will promptly take steps to delete such information and terminate the Child’s Account.

Further, if you are under the age of 18, or the age of consent in the applicable jurisdiction, you must have the consent of your parent or guardian in order to consent to this Privacy Policy, our Terms of Use, and use the Services.

12. Redress/Compliance and Accountability

If you have any questions about our privacy practices or this Privacy Policy, please contact Operam by email as described below. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

13. Other Rights and Important Information
13.1 Changes To Our Privacy Policy and Practices

This Privacy Policy may change from time to time. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted on the Services. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Services.

Revision to the Privacy Policy. We may revise this Privacy Policy in our sole discretion, so review it periodically. If you continue to visit this Site and use the services made available to you after such changes have been made, you hereby provide your consent to the changes.

Posting of Revised Privacy Policy. If there are any material changes to this Privacy Policy, Operam will notify you by email or as otherwise required by applicable law. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Operam will endeavor to comply with the law or contract.

13.2 California Privacy Rights

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Operam does not share Personal Information with Third Parties for their own marketing purposes.

14. Definitions

The following capitalized terms shall have the meanings herein as set forth below.

“Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Operam or to which Operam discloses Personal Information for use on its behalf.

“Employee” refers to any current, temporary, permanent, prospective or former employee, director, contractor, worker, or retiree of Operam or its subsidiaries worldwide.

“Personal Information” is any information relating to an identified or identifiable natural person.

“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.

“Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Operam or Operam’s Agents.

15. Contact us

If you would like to contact us about our privacy practices, or exercise any of your data subject rights, please send a written request to the data controller of your Personal Information or to Operam at or Privacy Office, 1041 N. Formosa Ave., Formosa West Bldg. #500, Los Angeles, CA 90046.


By using the Services, you hereby accept all of the terms set forth in our Privacy Policy. If you do not agree to accept all or any portion of such terms, then you are respectfully asked not to use the Services. Your continued use of the Services following the posting of such modifications, alterations or updates will signify your acceptance thereof.

18.1 The below table sets forth how we may process data received by a user entitled to the protections of the GDPR.



Contractual necessity

• Data processed must be necessary for the Services (or the purchase of products or services, as applicable) and defined in an agreement between a user and the Company


  • Requires a freely given, specific, informed and unambiguous consent by clear affirmative action, including any consent provided in this Privacy Policy
  • Users have a right to withdraw consent, which must be brought to their attention
  • Must be from a user over the age of consent in the applicable jurisdiction, otherwise given by or authorized by a parent / guardian
  • Explicit consent is required for some processing (e.g., special categories of Personal Information)

Legitimate interests

  • If a business or a third party has legitimate interests which are not overridden by a user’s rights or interests.
  • Processing must be paused if an individual objects to it
17.1 “Data controller” and “data processor” are important concepts in understanding a company’s responsibilities under the GDPR. Depending on the scenario, a company may be a data controller, data processor or both, and will have specific responsibilities as a result: A company is a data controller when it has the responsibility of deciding why and how (the “purposes” and “means”) the Personal Information is processed.
17.2 Under the GDPR, data controllers must adopt compliance measures to cover how data is collected, what it’s used for and how long it’s retained. They will also need to make sure people can access the data about them. Data controllers must ensure data processors meet their contractual commitments to process data safely and legally. This Privacy Policy sets forth and discussed all matters in relation to our activities, if any, as a data controller.
17.3 A company is a data processor when it processes Personal Information on behalf of a data controller. Under the GDPR, data processors have obligations to process data safely and legally. This Privacy Policy sets forth and discussed all matters in relation to our activities, if any, as a data processor.
17.4 Any transfer of Personal Information outside of the EEA (European Economic Area) must meet certain legal requirements. To the extent we are in receipt of Personal Information being transferred from inside the EEA to any region outside the EEA, we will at all times comply with applicable restrictions.
17.5 To the extent that we operate as a data controller and/or processor, our workplace will at all times be cognizant of applicable restrictions, and comply therewith.