Last updated: September 01. 2024

‍At OHM Agency (hereinafter – "OHM", "we", "us", "our", etc.), being a data-driven company providing various marketing and data analytics solutions, we respect your privacy and are committed to protecting your personal data. This Privacy Policy (hereinafter – “Privacy Policy” or “Policy”) outlines how we collect, store, use, share and process your personal data when you interact with our websites, namely: https://ohm.agency/; https://www.smalldata.app/; https://influmtr.com/; as well as any official Ohm.agency/smalldata.app/influmtr.com third level domains or subdomains or any other websites which refer directly to this Privacy Policy (hereinafter – “Websites”). For the purposes of this Policy Website shall be considered as a software product.This policy also explains your rights under the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), including the California Privacy Rights Act (CPRA).

1. Key definitions
• GDPR refers to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

• CCPA (CPRA) refers to California Consumer Privacy Act of 2018 as amended by California Privacy Rights Act (CPRA) of 2020.

• Personal Data or Personal Information refers to any information relating to an identified or identifiable person or household who can be directly or indirectly identified or reasonably linked by reference to an identifier. This definition provides for a wide range of personal identifiers to constitute Personal Data, including an email address, identification number, device information, location data, or online identifiers, such as cookie files or similar technologies. This definition, when used in this Policy shall have the meanings attributed to the terms “Personal Data” and “Personal Information” by GDPR and CCPA (CPRA) accordingly.

• Data Processing refers to any operation or set of operations performed on Personal Data or on sets of Personal Data, whether by automated or non-automated means, such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure, or destruction.You, Yours, etc. refers to a data subject (under GDPR) or consumer (under CCPA (CPRA)) who is a visitor of the Websites, signing up or registered, or authorized user (if applicable) or prospective/existing clients communicating with us via special contact form on the Websites, via email or by other means.

• Data Controller refers to a person who (either alone or jointly with other persons) determines the purposes for which, and the manner in which, any Personal Data is, or is to be, processed. For the purposes of this Policy (and processing activities described in this Policy only), the Data Controller is OHM INFLUMTR LTD registered under the laws of Cyprus under the number HE 432790 with a legal address at 19, Bouboulinas, 3032, Limassol, Cyprus, doing business as OHM.

• Data Processor, in relation to Personal Data, refers to any person (other than an employee of the Data Controller) who processes data on behalf of the Data Controller for business purposes. We describe how we engage with Data Processors and other third parties that may process Personal Data on our behalf in Section 4 of this Policy.

• Profiling refers to any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to Data Subjects. Profiling is normally done to analyze or predict aspects concerning that specific person’s preferences and interests while using a particular online-service.

All the other terms used in this Policy shall have the meaning assigned to them in accordance with the applicable law or terms of use of any of the online-sources comprising the definition “Websites” as described above.

2. What data do we process and how do we do that?
‍Within the course of your interaction with the Websites we may automatically collect or you can voluntarily provide us with the the following categories of your personal data which is further processed:
• Contact Information: Name, email address, phone number, and company details (for example, any information, provided through the “Contact Us” form published at the relevant Website).
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• Technical Data: IP address, device information, browser type, and operating system and other unique identifiers collected with cookies or other tracking technologies. This category may include device and connectivity information, such as IP address (Internet Protocol).

• Usage Data: Information about your interactions with our websites, products, and services.

• Marketing Data: Preferences, feedback, and responses to surveys or promotions (if applicable).

• Other data which allows us to indirectly identify Data Subject: any content that you provide to us whether through a form or field on our Website or any other communication, e.g. information about the company/brand/business you are related to, including but not limited to – the geography of business interests, nature of business, etc.

‍No children’s or sensitive data. Please note, that we do not collect or process any personal data which relates to sensitive (special) data categories under any applicable law (inc. GDPR and CCPA (CPRA)). It’s worth noting that we do not process data from children, as OHM is operating in the business-to-business sector and none of the Websites and products is intended solely for users aged 16 and above (or the age of maturity as defined by applicable local laws for independent use of Internet services). If you are under the specified age, you may only use the Websites with the involvement of a legal representative (guardian). Thus, we do not knowingly collect or process personal data from persons below this age. If there is any uncertainty, we will stop processing the questionable data and delete it. Neither do we collect or process sensitive (special) categories of Personal Data, including genetic or health data, without your explicit consent. Finally, we do not process data that you have explicitly requested us to stop processing or have opted out of in any other way.

Thus, your personal data described above may be collected in three different scenarios of your use of Websites:
• Direct Interactions with you: When you voluntarily provide information by filling out forms, registering at any of our Websites, or contacting us, or, for example, the information you are providing us with to enter into contractual relationships with us related to the usage of some of our products.
• Automated Technologies: We may collect your personal data automatically via cookies, server logs, and similar technologies that track your activities on our Websites. In this case, the information we collect is mostly formed by various online identifiers and other technical information about your session interaction with the Website and the device you use.
• Third Parties: We may receive some of your personal data from our business partners, analytics providers, and other service providers.

3. Legal basis and purposes of processing
‍We process personal data only when we have a valid legal basis for doing that. Our legal basis for collecting and processing personal data depends on the specific context in which we collect it. We rely on the following legal grounds:
• Consent: Where you have given your explicit consent through an explicit action, such as clicking a suitable consent-giving button or ticking a relevant box.
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• Contractual Necessity: Where the processing is necessary for the performance of a contract with you.

• Legal Obligation: Where we need to comply with a legal obligation set by any applicable law.

• Legitimate Interests: Where the processing is necessary for our legitimate interests and not overridden by your data protection interests or fundamental rights. These legitimate interests may include, but are not limited to, the following: maintenance of the clients list, maintenance of the Websites, improval of the Websites functions.

We process your personal data mainly to provide, operate, and maintain our Websites, products, and services, including SmallData, Influmtr, QueryVideo or for catching-up on your case when dealing with any request related to any of our past, current, or potential communications. See the description of the legal basis and purposes below:

Marketing communications.
Being a business pursuing stable growth, we believe that it is important to keep our clients and partners updated on the latest news of the online advertising industry, including, for example, creation of new OHM Agency’s (or other players’ of online advertising field) products or promotion campaigns which may help you to optimize the marketing of your products or launch a new outstanding project (commercial information). Moreover, we understand that it is important to you to stay updated on the negotiations and any other discussion that we may have with you regarding our past, current or potential collaboration. Thus, upon consent that you provide us when using particular functions of the Websites, we offer you the opportunity to subscribe to our marketing newsletters so as to receive such news and third-party ads. You can unsubscribe from direct marketing communications at any time by using the opt-out form in one of the received emails or by contacting us here [email protected].

4. Data sharing and transfers
‍By default, we collect your personal data only for our own use. However, within the course of providing you with the functionality of the Websites, we may share your personal data with:

• Service Providers: Third-party vendors that assist us with various business operations, such as hosting, data analytics, and marketing services.

• Affiliates: Companies related to OHM Agency that support our services.

• Business Transfers: In connection with any merger, sale, or transfer of our business assets.

• Legal Obligations: When required to comply with legal processes or regulatory requirements.

As a global company, OHM Agency may transfer your personal data to countries outside of your jurisdiction, including to countries that may not provide the same level of data protection as your home country. Thus, where required, we ensure that data transfers outside of the EU to the countries, in relation to which no ‘adequacy’ decision has been made by the European Commission, are subject to appropriate safeguards such as (SCCs) and other mechanisms.

‍Selling and sharing of personal data. We assure that we do not sell your personal data to any third party. However, we may share your personal information to our partners for business and commercial purposes. You have the right to opt out of sharing your personal information via contacting us here: [email protected].

5. Cookies and tracking technologies
‍A “cookie” is a small file containing information that is placed on your computer or other device when you visit and use a particular website, online service, feature, web-interface, or mobile application. Cookies allow the relevant cookie providers to gain information on how you interact with the relevant websites and which settings you used. This information also can help the providers to analyze ads performance and which offers may be the most relevant for you. The cookies themselves do not allow us to directly identify you without additional data, but they enable providers to create your online profile. The cookies may be either “first party cookies” (set by us) or “third party cookies” (set by third-party providers who work with us ).

We use technologies such as cookies, tags, and scripts. These technologies are used in order to provide, maintain, and improve the to optimize our offerings and marketing activities, and to provide you with a better experience, for example, to better secure the Websites, to fix bugs, and to maintain and improve the Websites functioning. For convenience and the purposes of this Policy, all those technologies are covered by the term “cookies”.

Below you can see the categories of cookies that may be used on our Websites:
• Necessary cookies. Necessary cookies are enabled for the assurance and function of a properly run website, and they cannot be disabled. These cookies do not store personal data that will be used for other purposes.
• Performance cookies. These cookies allow us to measure and improve the performance of our Websites. They help us know more about your experience when navigating the Websites.
• Functional cookies. These cookies enable us to provide enhanced functionality and personalization of the Websites and allow us to ensure you are having the best experience when interacting with the Websites. These may be set by us (first-party cookies) or by third-party providers who work with us (third-party cookies).
• (optional) Marketing cookies. These cookies allow for a more personalized and relevant advertising experience. OHM, or our advertising partners may use them to show you relevant ads on our Websites by uniquely identifying your browser and internet device. You can opt out of processing cookies of this type and of sharing them with our partners via special instrument through the cookie preferences section at our Website or at your browser’s settings.

Cookies stay on your device for a certain period of time, depending on their purpose. A “Session Cookie” is automatically deleted upon the completion of your session with us and you exit the browser, whilst a “Persistent Cookie” will remain on your device until you delete it or it expires.

6. Data security and confidentiality
‍We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, or destruction so as to keep the highest level of confidentiality as can reasonably be achieved. However, no security measure is infallible, and we cannot guarantee the absolute security of your data.

We retain your personal data for as long as necessary to fulfill the purposes for which it was collected and to comply with legal obligations. The retention period may vary depending on the type of data and the specific legal or operational needs. We also reserve the right to store various types of information (without any time limit) to use for analyzing our service performance, improving its features, providing services to you, and protecting the interests of OHM.

Meanwhile, we give you the opportunity to control and influence the time we store and process your data, as specified in the “Your Rights” section of the Policy.

7. Your rights
If  GDPR applies to you on any applicable grounds, you have the following rights:
• The right to be informed. In this Policy, we provide you with detailed information related to your personal data Processing.
• The right to access information held about you. i.e., you may always get information about your data that we process.
• The right to rectify your personal data if it is inaccurate, incomplete, or outdated.
• The right to erasure (deletion or removal) of your personal data. The right to restrict (block) processing. When processing is restricted, we will continue to store your personal data, but not process it any further.
• The right to data portability, which allows individuals to obtain and reuse their personal data for their own purposes across different services. This right allows users to easily move, copy, or transfer personal data from one IT environment to another in a safe and secure way, without hindrance to usability.
• Rights related to automated decision-making, including profiling, as stated in Article 22 of GDPR. We are not making any decisions which might produce a legal effect on you based on automated processing without legal grounds.
• The right to withdraw your consent (object) to direct marketing.
• The right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint with your local supervisory authority if you have a concern about our processing practices.

In addition, users subject to CCPA (CPRA) have following rights in relation to the personal information that we hold about you:
• Request to access information about the collection of personal information by us, as well as request the deletion of personal information.

8. Changes to this Policy
‍We may update this Policy from time to time to reflect changes in our practices or applicable legal requirements. When we make significant changes, we will notify you by updating the "Last updated" field at the top of this Policy and, when required, through additional notifications (e.g., via email or a prominent notice on our relevant Website).

9. Contact Us
‍If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

OHM INFLUMTR LTD
Gregoriou Xenopoulou 30, Limassol 3106, Cyprus
Email: [email protected]
Data protection officer contact: [email protected]

As the personal data may be controlled by the said entity jointly with its partners and affiliated parties, it is important to note that  the said legal entity is appointed as EU representative of such partners or affiliated parties in relation to matters concerning processing of personal data of the residents of the European Economic Area (EEA) or Switzerland, when such other joint controllers are located outside the EEA or Switzerland.