This Privacy Policy applies to OSI Consulting, Inc. (“OSI” “We” or “Us”). It applies to all Personal Information (defined below) that is collected by OSI through its online properties (the “Sites”) where this Privacy Policy is posted, as well as through offline sales and marketing activities.

The purpose of this Privacy Policy is to inform you of the kinds of information OSI may collect, how such information may be used, with whom such information may be shared, your choices regarding the collection, use and sharing of such information, your ability to access and correct such information and the security procedures OSI uses to protect this information.

By visiting the Sites and providing your Personal Information to OSI, you consent to the terms of this Privacy Notice, which forms a part of the Terms of Use for the Sites.

1. WHAT INFORMATION IS COLLECTED

Personal Information You Provide Directly

In general, when visiting the Sites or providing information through OSI’s offline sales and marketing activities, you have the choice of whether to provide personally identifiable information, i.e., information that identifies or could be used by, or on behalf of, OSI to identify an individual (“Personal Information”) through, for example, the Contact Us pages of the Sites. If you do, you are prompted only for certain basic information such as your name, the company you represent, your contact information, and anything you choose to include in the “message” text box. You will not need to disclose Personal Information such as your social security number, age, race, sex, religion, political affiliation, or home address.

Log Files, Research and Data Analytics

OSI or its vendors may also gather certain information automatically, such as Internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, operating systems, date/time stamps, and/or clickstream data. OSI uses Google Analytics, which collects and processes data from the Sites as explained here: www.google.com/policies/privacy/partners/. OSI gathers this information to better understand its customers and Sites’ user-base and to improve its services to you.

2. HOW COLLECTED INFORMATION IS USED

OSI uses the information that is collected about you for a variety of purposes, including: responding to emails, providing you with the products, services and support you request; processing your transactions; communicating with you about your account or transactions, changes to OSI policies and other administrative matters, your questions and comments; to better understand your interests in order to provide you with promotional information, relevant content, and other materials, consistent with applicable law and choices and controls you may have; improving OSI products, services and operations; ensuring compliance with OSI company policies and rules and the law; enforce the Sites’ Terms and Conditions; or as OSI believes is necessary to protect, enforce or defend the legal rights, privacy, safety or property of OSI and others, or other similar reasons.

3. HOW COLLECTED INFORMATION IS SHARED

Affiliates. OSI may share your information with OSI affiliates (companies that control, are controlled by, or are under common control with, OSI). These entities may use your information to make predictions about your interests and may provide you with special offers, promotions, advertisements, and other materials

Vendors, Service Providers and Sub-Contractors. OSI may share your information with vendors, service providers or sub-contractors that perform functions on its behalf, including operations, marketing, advertising, or website support among others.

Business Partners. OSI may share your information with business partners that OSI collaborates with on marketing initiatives, including, but not limited to, conferences, webinars and other projects.

Legal and Compliance Disclosures. OSI may also disclose your Personal Information:

– as required by law, such as to comply with a subpoena, legal proceedings, or similar legal process, including disclosure to authorized third party auditors; or

– when OSI believes in good faith that disclosure is necessary to protect OSI’s rights, protect your safety or the safety of others, investigate or prevent fraud, or respond to a government request, whether or not legally required.

Business Transitions. OSI may share your Personal Information if OSI goes through a business transition, such as a merger, acquisition, or sale of or transfer of assets.

Other Parties with Your Consent. In addition to the sharing described in this Privacy Policy, OSI may also share information about you with other third parties in other ways when you consent to such sharing.

4. HOW SECURE IS MY PERSONAL INFORMATION?

OSI takes reasonable steps to ensure that the Personal Information it collects about you remains accurate, timely and secure. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure and while OSI strives to protect your personal information, it cannot guarantee or warrant its complete security.

5. HOW CAN I CORRECT MY PERSONAL INFORMATION?

If you would like to change or verify Personal Information that you have submitted through the Sites, please contact Us so that OSI may update your information. OSI’s contact information is set forth below. OSI will use commercially reasonable efforts to accommodate all such requests.

6. HOW ARE THIRD PARTY LINKS HANDLED?

While you are using the Sites, you may be linked or directed to other third party websites outside the Sites that are beyond OSI’s control. Each of these third parties may have a privacy policy different from that of OSI. OSI is not responsible for any actions or policies of such third parties who collect information from you. You should review the applicable privacy policies of any third parties before providing Personal Information to such third parties.

7. DOES OSI USE COOKIES AND TRACKING TECHNOLOGIES?

Cookies. OSI uses cookies, web beacons and other similar technologies for various purposes, including to analyze trends, administer the Sites, track users’ movements around the Sites and to gather demographic information about its user base as a whole.

Cookies are small pieces of information that are stored on computer hard drives. A cookie enables the entity that put the cookie on your device to recognize it across different websites, services, devices, and browsing sessions. For example, OSI may use cookies to recognize you when you return to the Sites in order to provide you with a better user experience. OSI may allow third parties to use cookies on the Sites but OSI does not control the use or contents of third party cookies. Web browsers often allow you to configure the browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. If you elect to reject cookies, please note that you may not be able to take full advantage of the features and functions of the Sites.

Do Not Track Browser Requests.

Web browsers may allow you send “Do Not Track” requests. OSI does not currently take actions to respond to Do Not Track signals because there is no current industry standard concerning what, if anything, websites should do when they receive such signals. OSI may adopt a standard if and when one is created.

8. CHILDREN’S ONLINE PRIVACY PROTECTION ACT COMPLIANCE

The Sites are general audience websites and OSI does not knowingly collect Personal Information from anyone under 13 years of age. If you believe OSI may have collected information from your child on the Sites, please contact Us and OSI will make reasonable efforts to delete the information from its records.

9. MODIFICATIONS TO THIS POLICY

This Privacy Policy was last updated on the date listed at the bottom of this Policy. OSI reserves the right to change this Privacy Policy at any time. Any changes to this Policy will be effective immediately upon notice, which may be provided to you by posting the latest version on the Sites. Your subsequent use of the Sites will be deemed acceptance of such changes. Be sure to review this Privacy Policy periodically to ensure familiarity with its most current version. By using the Sites following the posting of changes to this Privacy Policy, you agree to all such changes.

10. WHAT IF I HAVE QUESTIONS?

OSI takes your privacy concerns seriously. If you believe OSI has not complied with this Privacy Notice, or have any other questions you may write to Us at 5950 Canoga Avenue, Suite 300, Woodland Hills, CA 91367 (Attn: General Counsel), email Us at privacy@osius.com, or call Us at (818) 992-2700.

Effective Date: April 21, 2017

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