O2G Privacy Policy


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Introduction


O2G, LLC. values the privacy of individuals who use our domain/websites (including o2gcoin.com, o2gpay.com (the “Website” or “Site”)), applications, or services, and any services that link to this Privacy Policy (collectively, our “Services”). By accessing or using our website, platform, including our website, web app, mobile app, products, or services (collectively, our services), you indicate that you understand, accept, and consent to the practices described in this policy. This privacy policy (the “Privacy Policy”) explains how we collect, use, and disclose Personal Data from users of our Software, Site, and Services. For the purposes of this Privacy Policy, “Personal Data” means information that relates to an identified or identifiable natural person.


We may modify this Privacy Policy from time to time which will be indicated by changing the version at the top of this page. If we make any material changes, we will notify you by email (sent to the email address specified in your account), by means of a notice on our Services prior to the change becoming effective, or as otherwise required by law.


We believe and adhere to transparency, integrity, fairness and adherence to the rule of law. Except as described in this Privacy Policy, O2G LLC will not give, sell, rent or loan any personal information to any third party.O2G LLC collects personal information which is required under the law to open a O2G Account, for any activity including transactions.


What information we collect


We collect information from you by asking you directly for it, this includes when you interact with our website.

To establish an account and access our services, we will ask you to provide us with some information about yourself. This information is either required by law (e.g., to verify your identity), necessary to provide the requested services


We may collect the following types of information from you.

  1. Personal identification information: such as your full legal name, date of birth, phone number, email address, bank account details, nationality, gender, signature, utility bills, photographs, phone number, home address, information about family members, and email.

  2. Formal identification information: including government issued identity document such as passport, driver license, national or state identity card, tax identification number, social insurance number (or any comparable identification number issued by a government), social security card, passport number, driver license details, national identity card details, visa information, and/or any other information deemed necessary to comply with our legal obligations under financial, anti-money laundering or counter terrorism financing laws.

  3. Employment information: including employment or occupation industry, office location, job title, and/or description of role, employer identification number (or comparable number issued by a government)

  4. Additional information: including responses to questions that we are specifically required to ask or information that we are required to obtain in order to meet our regulatory, compliance or other legal obligations, such as questions about the source and the intended use of any funds or digital assets; proof of legal formation (e.g., articles of incorporation), personal identification information for all material beneficial owners; bank account information, payment card account number, transaction history, trading data; information about the transactions you made or intend to make.

  5. Other information: our compliance team may request additional information from you, as may be required for compliance with law, regulations or our internal policies. This may include information relating to health, travel history, relationship/marital status and criminal convictions or charges.


Why we need to collect this information


Most of our services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. For example, we must identify and verify customers using our services in order to comply with anti-money laundering and counter terrorism financing laws across the jurisdictions in which we operate. This may include the collection and storage of your photo identification and other documents you provide to us.

In addition, we use third parties to verify your identity by comparing the personal information you provide against third-party databases and public records. We may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk as required under applicable law. If you do not provide personal information required by law, we may have to close your account.


We process your personal information in order to administer and protect our business, prevent and mitigate fraud, criminal activity, or misuses of our services, and to ensure the security of our systems, architecture and networks, and to protect you against account compromise or funds loss

With whom do we share your information?


Regulatory and Government Authorities


We may share your information in order to meet our legal obligations, including our know-your-customer and anti-money-laundering obligations. We are required to validate our clients’ identities by applicable laws and regulatory requirements and rely on third-party services to perform these validations. Personal information that you provide to us during the account opening process is passed to these service providers at account opening and on an ongoing basis thereafter.

We may share your information in order to protect our legal rights. We may disclose or transfer information we collect upon account closing where you have a deficient balance.

We may also share or transfer your personal information, in accordance with applicable law, to a buyer of our company, or substantially all of its assets. You acknowledge that such transfers may occur, and that any purchaser of or successor to our business or its assets may continue to collect, use and disclose your information as set forth in this policy


Service Providers / Partners


Personal information will only be shared in the following instances:


  1. O2G shall share information with Plaid in accordance with this Privacy Policy. Information shared with Plaid is treated by Plaid in accordance with its privacy policy, available at https://plaid.com/legal/.


  2. In addition, O2G share your personal information with Sila in connection with O2G KYC/KYB and Payment processing services. O2G requires that these service providers only use your information in connection with the services that they perform for O2G and prohibit such service providers from selling your information to anyone.


  3. O2G will also share your information with Evolve Bank with which O2G partners in order to process payments and transactions that you authorize.


  4. O2G may also utilize your personal information and share such information with law enforcement, government officials, or other third parties when O2G is compelled to do so by subpoena, court order, or similar legal procedure or when O2G believes in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of the O2G Terms of Use or any other applicable policies.


  5. Personal information is shared with third party identification services in order to prevent fraud. These services help O2G confirm your identity by comparing the information that you provide us to public records and other third-party databases. These third-party service

providers may create derivative data based on your personal information that can be used solely in connection with provision of identity verification and fraud prevention services.


Electronic Fund Transfers (EFTs) and Account Balances. O2G LLC partners with financial services software company Sila Inc. (Sila) and banking services provider Evolve Bank & Trust (Evolve), member FDIC, to offer you electronic fund transfers (EFTs). When you create a O2G LLC account, link a bank account, or initiate an EFT, you are authorizing us to share your identity and banking information with Sila and Evolve to support your account. You are also agreeing to the terms of Sila’s privacy policy, https://silamoney.com/privacy-policy/, Evolve’s privacy policy, https://www.getevolved.com/privacy-policy/, and Evolve’s communications consent and disclosure, https://silamoney.com/evolve-electronic-communications-consent-and-disclosure/ (the “Partner Terms”). It is your responsibility to make sure the data you provide us is accurate and complete, which is necessary for our partners to process EFTs on your behalf. The Partner Terms may be modified from time to time, and the governing versions are incorporated by reference into this Privacy Policy. Any term not defined in this section but defined in the Partner Terms assumes the meaning as defined in the Partner Terms. IT IS YOUR RESPONSIBILITY TO READ AND UNDERSTAND THE PARTNER TERMS BECAUSE THEY CONTAIN TERMS AND CONDITIONS CONCERNING YOUR O2G LLC ACCOUNT, INCLUDING BUT NOT LIMITED TO USE OF YOUR PERSONAL INFORMATION.


RETENTION OF PERSONAL INFORMATION:


O2G will retain your personal information for a minimum of five (5) years, or as necessary to comply with O2G’s legal, regulatory and compliance obligations, or as needed in order to resolve any disputes


CHILDREN'S PERSONAL INFORMATION


Our services are not meant for persons under the age of majority or younger than 18 years. We do not knowingly or intentionally collect personal information from such persons. If we learn that we have inadvertently gathered personal information about such a person, we will take legally permissible measures to remove that information from our records. We will require such a user to close his or her account and will not allow the use of our products and services. If you are the parent or

guardian of a minor and you become aware that he or she has provided personal information to us, please contact us at info@o2gpay.com.


YOUR PRIVACY RIGHTS AND CHOICES


Opt-out

You may contact us anytime to opt-out of: (i) automated decision-making and/or profiling; (ii) any new processing of your Personal Data that we may carry out beyond the original purpose;

(iii) any consent you previously provided to us regarding the processing of your Personal Data; or (iv) the transfer of your Personal Data outside the EEA. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent. Please note that your use of parts of our Website may be ineffective upon opt-out.


Access/Amend/Restrict

You may access the information we hold about you by contacting us via the “Contact Information” section below. You may update or correct any inaccuracies in your Personal Data by contacting us via the “Contact Information” section below. You may request us to restrict the processing of your Personal Data, or object to our processing of your Personal Data via the “Contact Information” section below. Your Personal Data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.


Erase

In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you may request that we erase your data


If you wish to exercise any of these rights, please contact us at support@o2gpay.com. In your request, please clearly describe: (i) what Personal Data is concerned and (ii) which of the above rights you would like to enforce. For your protection, we only process requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before processing your request. We will try to comply with your request as soon as reasonably practicable and, in any event, within thirty (30) days of your request. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason for such retention.


CALIFORNIA PRIVACY RIGHTS


Your California Privacy Rights If you are a California resident, you may exercise the following rights. Right to Know and Access. You may submit a verifiable request for information regarding the: (i) categories of Personal Information collected, sold, or disclosed by us; (ii) purposes for which categories of Personal Information are collected or sold by us; (iii) categories of sources from which we collect Personal Information; (iv) categories of third parties with whom we disclosed or sold Personal Information; and (v) specific pieces of Personal Information we have

collected about you during the past twelve months. Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you. Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. Please note that, unless you have contacted us for customer support, signed up for our newsletter, or otherwise provided us with your identifiable personal information, we will have no reasonable method by which we can identify you and will be required to deny your request. To verify your access or deletion request, we may request that you provide us with some information that matches the identifying information that you have already provided to us.Right to Opt Out. In some circumstances, you may opt out of the sale of your Personal Information. We do not sell your Personal Information. Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations. Shine the Light. We do not rent, sell, or share Personal Information with non-affiliated companies for their direct marketing uses as contemplated by California’s “Shine the Light” law (Civil Code § 1798.83), unless we have your permission. Submit Requests. To exercise your rights under the CCPA, please email us via our Contact Information section.


SECURITY


We use reasonable organizational, technical, and administrative measures to protect Personal Data within our organization. However, as no electronic transmission or storage of Personal Data can be entirely secure, we can make no guarantees as to the security or privacy of your Personal Data. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us at support@o2gpay.com.


COMPLAINTS


We are committed to resolve any complaints about our collection or use of your Personal Data. If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at at support@o2gpay.com. We will reply to your complaint as soon as we can and, in any event, within thirty (30) days. We hope to resolve any complaint brought to our attention; however if you feel that your complaint has not been adequately resolved, you have the right to contact your local data protection supervisory authority.


CONTACT INFORMATION


We welcome your comments or questions regarding our privacy practices. If you have questions about your privacy related to the Site or Services or this Privacy Policy, you may contact us at support@o2gpay.com