Omal’s privacy policy

This Omal Don Spater Privacy Policy (“Privacy Policy”) is effective from and after the date shown above, and describes how omaldonspater.com (collectively, the “Company,” “I,” “me,” “we,” “our,” or “us,”) collects, uses, shares, and otherwise processes information collected about you when you use our platform as further described in the “How We Use The Information We Collect About You” section below, and any website or location offered by us that directly links to this Privacy Policy (herein referred to as the “Service”).

If you are a Virginia, Colorado, Utah, or Connecticut resident, please see the “Additional Disclosures for Virginia, Colorado, Utah, or Connecticut Residents” section.

If you are a California resident, please see the “Additional Disclosures for California Residents” section.

If you are a data subject in the United Kingdom or any part of the European Economic Area, please see the “Additional Disclosures for People in Europe” section.

If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section.

01.

THE INFORMATION WE COLLECT ABOUT YOU

The Company collects personally identifiable information from you when you use the Service. This information is collected and stored electronically by us. This information may be provided to us voluntarily by you, collected automatically by us from you, or provided to us from third-party sources

A. Information You Voluntarily Provide

We collect information about you when you use the Service, including information you provide when you register an account, update your profile, access our content, make a purchase, participate in a promotion or incentive program, or contact customer support. The categories of information that you may voluntarily provide and that we have collected in the last twelve (12) months for our business purposes include:

• Contact Information, including name or email address when you reach out to us for support or other communications;
• Account Credentials, including account password;
  Digital Wallet Information, including your public wallet address;
• Demographic Data, including your age, gender, and country; Billing Data, including your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments.
• Profile Information, including information and achievements you display as part of your account profile; and
• Content, including any content in communications with us that you provide.

We use a third-party payment processor to process payments concerning any purchases you make using the Service. Your payment information will be provided directly to the payment processor, and not to the Company.

You may choose to voluntarily provide other information to us that we do not request; in such situations, we have no control over what categories of personal information such disclosure may include. Any additional information provided by you to us is provided at your own risk.

B. Information Collected Automatically

When you use the Service, we will automatically process limited information. The information we may have collected automatically over the twelve (12) months for our business purposes includes the following:

• Service Data, including data about features you use, pages you visit, emails and advertisements you view, products and services you view and purchase, the time of day you browse, and your referring and exiting pages.
• Device Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address.
• Log Files, which are files that record events that occur in connection with your use of the Service.
• Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level).
• Cookies are small data files stored on your device that act as a unique tag to identify your browser. Please see the section entitled “Cookies” below for more information about the cookies we use and why we use them.

C. Information From Third Party Sources

In limited circumstances, we may receive information from third-party sources. Information we may have collected about you from a third party in the last twelve (12) months for our business purposes includes the following:

• Partners, that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
• Publicly available sources, including data in the public domain, such as but not limited to applicable blockchain transaction records (collectively, the “Blockchain”)

02.

HOW WE USE THE INFORMATION WE COLLECT ABOUT YOU

We use the information we collect from and about you for the following business purposes:

• To provide, maintain, improve, and enhance our Service;
• To understand and analyze how our Service is used and develop new products, services, features, and functionality;
• To sell you our products and services and fulfill any purchases;
• To conduct research, including focus groups and surveys;
• To communicate with you, provide you with updates and other information relating to our Service, provide information and/or perform services that you request, respond to comments and questions, and otherwise provide customer support;
• To find and prevent fraud, and respond to trust and safety issues that may arise;
• For compliance purposes, including enforcing our legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
• To fulfill any other business or commercial purposes at your direction or with your notice and/or consent.

For information on your rights and choices regarding how we use personal data about you, please see the section entitled “Your Rights and Choices” below.

03.

SHARING OF INFORMATION

We share the information we collect under the practices described in this Privacy Policy. The types of entities we may have shared information with or may share information with in the future, include the following:

• Third Parties Providing Services On Our Behalf. To make various features, services, and materials available to you through the Service, host the Service, process payments, and respond to your requests and inquiries, we may share the information you provide with third parties that perform functions on our behalf.
• Business Partners. We share information with Business Partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities.
• Blockchain Platform. When you engage in a transaction that is recorded on the Blockchain, certain information that may be considered personal data related to that transaction will be recorded on the Blockchain permanently across a wide network of computer systems and be incapable of deletion, and may be accessible to third parties not controlled by the Company. Many Blockchains are open to forensic analysis which can lead to deanonymization and the unintentional revelation of personal data, especially when Blockchain data is combined with other data.
• Business Transfers. We share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale, or any other type of acquisition, the business combination of all or any portion of our business or assets, change of control, or a transfer of all or a portion of our business or assets to another third party (including in the case of any bankruptcy proceeding).
• Legal Disclosure. Under certain circumstances, we may be required to cooperate with legal investigations, and/or we may be subject to legal requirements to disclose information collected through the Service, such as by court or a governmental agency. We may also disclose personal data to investigate any violation or potential violation of the law, this Privacy Policy, our Terms of Use, or any other terms of use related to your use of the Service, or to protect or defend the rights and property of the Company.
• Consent. We share information with notice to you and your consent.

Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated and/or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the section entitled “Your Rights and Choices” below.

04.

COOKIES

What are cookies? A cookie is a small file containing a string of characters that is sent to your computer when you visit a website or use an online service. When you visit the website or use the service again, the cookie allows that website or online service to recognize your browser or device. Cookies may store unique identifiers, user preferences, and other information.

What is the duration of cookies? We may use “session cookies” or “persistent cookies.” Session cookies are temporary and expire once you close your browser or once your session ends. Persistent cookies remain on your device for much longer or until you or your browser erase them. Persistent cookies have varying durations that are dependent on their expiration date.

What types of cookies do we use? The Company uses the following cookies with its Service:

• Necessary Cookies. These cookies are necessary for you to browse the Service and use its features, such as accessing secure areas of the Service. Without these cookies, certain aspects of the Service may not be available to you.
• Preferences Cookies. These cookies collect information about how you have used the Service in the past and allow the Service to remember the choices you have made. These cookies allow us to improve how the Service works for you and tailor the Service to your preferences.
• Statistics Cookies. These cookies collect information about how you use the Service, such as which pages you most often visit on the Service, the time you spend on the Service, which links you click on, and any issues encountered. These cookies help us understand how visitors interact with the Service. All information collected is aggregated and does not identify you.
• Marketing Cookies. These cookies track your online activity to help deliver advertisements that are relevant to you and your interests and measure the effectiveness of the advertising campaigns. They also limit how many times you see a certain advertisement. We may share the information collected through these cookies with others, such as advertisers.

Why do we use cookies? Cookies help us improve the Service by providing us with information about which parts of the Service are most popular, enabling us to analyze technical and navigational information about the Service, and helping us to detect and prevent fraud. We also use cookies and other data collection tools (such as web beacons and server logs) to help improve your experience with the Service. For example, we use analytic service providers to help analyze how users use the Service. These tools use cookies to collect standard Internet log information and visitor behavior information in an anonymous form. The information generated by the cookie about your use of the Service (including your IP address) is transmitted to our data collection tool service providers. This information is then used by us to evaluate visitors’ use of the Service and to compile statistical reports on website activity for the Company.

For more information concerning your rights and choices related to cookies, please see the section entitled “Your Rights and Choices: Cookies and Other Tracking Technologies” below.

05.

ANALYTICS

We use analytics services, such as Google Analytics, to help us understand how users access and use the Service, as well as help us understand market trends and the popularity of our products and services. As part of this process, we may incorporate tracking technologies into our own Service (including our website and emails). For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.

06.

YOUR RIGHTS AND CHOICES

A. Accounts

You may access, update, or remove certain information that you have provided to us through your account by visiting such account settings or sending an email to the email address set out in the “Contact Us” section below. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

B. Communications

You can opt-out of receiving promotional emails from us at any time by following the removal instructions in the specific communication that you receive or emailing us at the email address provided in the section entitled “Contact Us” below with the word UNSUBSCRIBE in the subject field of the email. Note that your opt-out is limited to the email address used.

C. Cookies and Other Tracking Technologies

Consider the following concerning cookies and other tracking technologies:

• Cookies. Most browsers accept cookies by default. By changing your browser settings, you can instruct your browser to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
• Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, that there is no industry consensus as to what site and app operators should do regarding these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action concerning “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Please be aware that if you disable or remove tracking technologies, some parts of the Service may not function correctly.

D. Analytics

Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.

7.

DATA SECURITY

The Company uses reasonable security measures designed to prevent unauthorized intrusion into the Service and the alteration, acquisition, or misuse of personal data. Nevertheless, transmission via the Internet is not completely secure and we cannot guarantee the security of information about you, collected from you, or submitted by you. We will not be responsible for the loss, corruption, unauthorized acquisition, or misuse of information that you provide or that we collect through the Service that is stored by us or our service providers, or for any damages resulting from such loss, corruption, or unauthorized acquisition or misuse.

8.

CHILDREN’S PRIVACY

The Service is not directed towards, nor was it designed to attract the attention of any children, and we do not knowingly collect or maintain personal data from any person under the age of thirteen.

09.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your email address, by informing you about such changes through our website and/or via other channels we may use to communicate with you.

10.

CONTACT US

Please contact us at omaltrident@gmail.com if you have any questions or concerns about this Privacy Policy.

11.

ADDITIONAL DISCLOSURE FOR VIRGINIA, COLORADO, UTAH, AND CONNECTICUT RESIDENTS

A. Notice At Collection

To learn more about the categories of personal information we collect about you, review the section entitled “Information Collection” above. We collect and use these categories of personal information for the business purposes described in the section entitled “How We Use the Information We Collect About You” above.

B. Your Rights

If you are a resident of Virginia, Colorado, Utah, or Connecticut, you have the following rights enumerated under the applicable law:

• Right to Know and Access. You have a right to request that we disclose, what personal information we’ve collected about you.
• Right to Delete. You have a right to request that we delete your personal information.
• Right to Correct. You have a right to ask that the Company correct the personal information it has about you, subject to certain exceptions.
• Right to Opt-Out. You have a right to opt-out of the sale or use of your personal information for targeted advertising.
• Right to Non-Discrimination. You have a right not to be discriminated against for the exercise of your rights described herein.

To exercise any of these rights, please email us at omaltrident@gmail.com – In the request, please specify which right you are seeking to exercise and the scope of the request. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests.

12.

ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENT

A. Notice At Collection

In the past 12 months, we have collected the following categories of personal information enumerated in the California Consumer Privacy Act (“CCPA”):

Identifiers, including name, email address, IP address, and an ID or number assigned to your account.
Source of Collection: We collect this category of information from you directly or automatically
from your device(s). We also may collect this information from our service providers.

• Identifiers, including name, email address, IP address, and an ID or number assigned to your account. Source of Collection: We collect this category of information from you directly or automatically from your device(s). We also may collect this information from our service providers.
• Demographic Information, including information related to your age and gender. Source of Collection: We collect this category of information from you directly.
• Commercial information, including purchases and engagement with the Services. Source of Collection: We collect this category of information from you directly, from third-party sources, or automatically from your device(s).
• Internet activity, including your interactions with our Service. Source of Collection: We collect this category of information from you or your device(s) when you provide it to us or interact with us online (such as through our Service, as defined above, or our social media). We also collect this information from third parties such as online advertising networks, online data aggregators, and social networks.
• Geolocation data, including location-enabled services such as WiFi and GPS.
  Source of Collection: We collect this category of information from you or your device(s) when you provide it to us or interact with us online (such as through our Service).
• Inferences, including information about your interests, preferences, and favorites. Source of Collection: We draw inferences about you from the information we collect from you or your device(s) when you provide it to us or interact with us online (such as through our Service). We also draw inferences about you from the information we collect from third parties
  such as financial institutions, payment processors, and social networks.

For more information on the information we collect, including the sources we receive information from, review the section entitled “The Information We Collect About You” above. We collect and use these categories of personal
information for the business purposes described in the section entitled “How We Use the Information We Collect About You” above.

B. Your Rights

If you are a California resident, you have the following rights concerning your personal information:

• Right to Know: You have a right to request that we disclose, up to two times per year, what personal information we’ve collected about you.
• Right to Delete. You have a right to request deletion of your personal information, subject to certain exceptions.
• Right to Correct. You have a right to ask that the Company correct the personal information it has about you, subject to certain exceptions.
• Right to Opt-Out of the Sale or Sharing of Your Personal Information. You have a right to opt-out of the sale or sharing of your personal information (as those terms are defined in the CCPA).
• Right to Non-Discrimination. You have a right to exercise the above rights without being discriminated against.

To exercise any of these rights, please email us at omaltrident@gmail.com – In the request, please specify which right you are seeking to exercise and the scope of the request. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may
deny your requests to know or delete.

C. Notice of Sale and Sharing

We do not sell or share (as those terms are defined in the CCPA) your personal information that is collected by us when you use our Service.

D. Authorized Agent

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

E. Right to Non-Discrimination

You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.

13.

ADDITIONAL DISCLOSURES FOR PEOPLE IN EUROPE

A. Roles And Data Controller’s Contact Details

GDPR and data protection laws in Europe distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”).

The Company acts as a controller with respect to personal data collected as you interact with our Service. You can contact us by email at the address indicated above in the section entitled “Contact Us” above.

B. Lawful Basis For Processing

GDPR and data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include the following:

• To fulfill obligations in the contract between you and the Company. To use our Service, you and the Company entered into an agreement under the Company’s Terms of Use, and for the Company to fulfill its obligations with respect to providing the Service under such agreement, we have to collect your personal information to provide the necessary functionality as further described above entitled “The Information We Collect About You”.
• To pursue our legitimate interests. We rely on legitimate interests pursued by us to process your information, including understanding how our Service is functioning, improving our Service, developing new products, and preventing fraud. To pursue the foregoing, we will process personal information. Where we rely on legitimate interest, we carry out a balancing test to weigh our interests against your right to personal data protection, our processing will never override your fundamental rights and freedoms, and you can always exercise your right to object to such processing.
• Consent. In certain situations where you provide us with consent, we may process your information.
• To comply with the law. In limited circumstances, we may process information in order to comply with legal obligations. To the extent we have received such information from third parties where we have agreed to contractual requirements such as standard contractual clauses, we will use our reasonable efforts to dispute making such disclosures unless legally required to do so.

C. Retention Of Information

D. Once the purpose of processing is fulfilled, we retain personal data for no longer than the applicable statutory limitation period. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements. We will delete or anonymize personal data once the applicable retention period has expired. Data Transfer

If GDPR applies and your data is transferred outside the UK or the EEA to the United States or any other country, we will transfer your personal data subject to appropriate safeguards, such as an adequacy decision by the European Commission based on Article 45 of Regulation (EU) 2016/679, or Standard Contractual Clauses as provided from time to time by the European Commission. You can receive additional information on where your data is transferred, and which are the appropriate safeguards by contacting us.

E. Your Data Subject Rights

Your Rights. If you are a data subject according to the GDPR, subject to certain conditions you have the right to:

• access, rectify, or erase any personal data we process about you;
• data portability, asking us to transfer to any third party at your choice;
• restrict or object to our processing of personal data we process about you; and
• where applicable, withdraw your consent at any time for any data processing

How to Exercise Your Rights. You may exercise your rights by submitting a written request to us at the email address set out in Section 10 above entitled “Contact Us”. We will respond to your request within thirty (30) days. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

F. Complaints

If you have a complaint about our use of your personal data or a response to your requests regarding your personal data, you may submit a complaint to the Data Protection Supervisory Authority in your jurisdiction. We would, however, appreciate the opportunity to address your concerns before you approach a data protection regulator, and would welcome you directing an inquiry first to us.

In addition to our contact details indicated above, you can also contact our Designated Individual Overseeing Compliance with this privacy policy by emailing omaltrident@gmail.com or writing us at:

OMAL DON SPATER PRIVACY POLICY

omaltrident@gmail.com

spaterpublications@gmail.com