Privacy policy

 

Origin Exchange LLC  (collectively “Origin Exchange”,” “we,” “us,” and “our”), respects your privacy. This Privacy Policy together with our Privacy Statement and our Cookie Policy (collectively the “Privacy Policy“) explain the accepted privacy practices for Origin Exchange’s online services and product offerings at originexchange.com (the “Services” and the “Website”, respectively). They describe the ways in which your information is collected and used by Origin Exchange, and the rights and options available to you with respect to such information. The Privacy Policy incorporates by reference the most current version of the User Agreement posted on Origin Exchange’s Website (“User Agreement”). 

Privacy Shield

Origin Exchange complies with the EU-U.S. Privacy Shield Framework (“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from European Union member states to the United States and other locations. Origin Exchange is going through the steps to certify to the Department of Commerce that it adheres to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. Origin Exchange Services are operated via servers situated in various geographic areas, including the United States. Your information may be processed in any of these areas as allowed by Privacy Shield and further controlled by individual service agreements. Your use of the Services constitutes consent to processing in any of these areas. Origin Exchange accepts full accountability and responsibility for the protection of your information according to applicable privacy legislation, the Privacy Shield, this Privacy Policy and the Privacy Policy including during the course of any onward transfers to third parties.

Information Collected

Your use of the Services will result in the collection and processing of a variety of information. This may include, products purchased, products being sold, membership profile, voice recordings, emails, chat transcripts and other records of your contacts in addition to information about your employees (for sellers on the website). More detail about the information collected is contained in your service contract.

Your use of the Services is Origin Exchange’s legal basis to process the information in accordance with the Services’ capabilities and features. You must not use the Services on information that you do not have a legal basis to process.

Use of Information

We will process the information you provide through the Services for the following purposes in addition to those outlined for the individual services in your service contract:

  • To provide the Services and to enable you to use them;
  • To process the information you provide as directed by you;
  • To improve and expand the Services, including to create new services which correspond to the requirements and expectations of the users of the Services and to modify or cancel existing Services and content. The information used for this purpose will not identify you personally;
  • To improve and customize your experience and other users’ experience with the Services;
  • To contact you as and when Origin Exchange believes it to be necessary for technical, administrative or security reasons;
  • To analyze and provide statistical information to third parties. This information will not identify you personally;
  • For the orderly and proper operation and development of the Services; or
  • For any other purpose specified in this Privacy Policy and/or in the User Agreement.

Transfer of Information to Third Parties

Origin Exchange will not transfer your information to any third party, except in the following cases or as otherwise outlined in this Privacy Policy:

  • As required to provide the Services and enable you to use the Services and disclosed to you;
  • If Origin Exchange reasonably believes that you have breached the User Agreement, or abused your rights to use any of the Services, or performed any act or omission that Origin Exchange reasonably believes to be violating any applicable law, rules, or regulations. Origin Exchange may share your information in these cases, with law enforcement and other competent authorities and with any third party as may be required to handle any result of your wrongdoing;
  • If Origin Exchange reasonably believes that it is required by law to share or disclose your information in order to prevent, investigate, or take action regarding illegal activities. In addition, to establish or exercise our legal rights or defend against legal claims;
  • As permitted or required by, or in response to lawful requests by applicable local law enforcement agencies or regulatory agencies, or agencies with responsibility to oversee and enforce national security;
  • In any case of dispute, or legal proceeding of any kind between you and Origin Exchange, or between you and other users or third parties with respect to, or in relation with the Services;
  • In any case where Origin Exchange may reasonably believe that sharing information is necessary to prevent serious damage to your person or property or to the person or property of any third party;

If Origin Exchange organizes the operation of the Services within a different framework, or through another legal structure or entity, or if Origin Exchange is acquired by, or merged with another entity, provided however, that those entities agree to be bound by the provisions of this Privacy Policy;

Origin Exchange may share information with companies or organizations connected to or affiliated with Origin Exchange, such as subsidiaries, sister-companies, parent companies and service providers such as an email service provider to send you emails on our behalf, with the express provision that their use of such information must comply with this policy; or

Origin Exchange is also entitled to transfer or share anonymous, statistic or aggregative information with companies or organizations connected to Origin Exchange, and with suppliers, business partners, advertisers, and every third party, according to Origin Exchange’s absolute discretion; however, Origin Exchange will not disclose your identity to them, knowingly or deliberately, without receiving your consent.

APIs, SDKs and Plugins

We may use third-party APIs, plugins and software development kits (“SDKs”), which may allow third parties to collect personal information about you for various purposes, such as to conduct analytics, verify your business when you register with Origin Exchange, or provide customized content. For more information about our use of APIs, plugins and SDKs, contact us as described below.

Children’s Online Privacy Information

Origin Exchange does not knowingly collect information from minors who are under the age of 16 through the Services. If a parent or guardian becomes aware that his or her child has provided us with information without his/her consent, then he or she should contact Origin Exchange at the information described below. If we become aware that a child under the age of 16 has provided us with information, we will delete such information to the extent possible. Further, the Children’s Online Privacy Protection Act (“COPPA”) requires parental consent for collection of data from children younger than the age of 13 years old. For tips on protecting children’s privacy online, generally, please view the U.S. Federal Trade Commission (“FTC”) website at COPPA.

Cookies

In addition to the Cookie policy as part of the Privacy Statement, the use of the Services specifically requires the use of cookies, which are stored by your web browser in order to allow Origin Exchange to store preferences and enable other functions. These cookies are essential to use the Services.

Customer Proprietary Network Information Notice

Origin Exchange offers communications-related services, including local and long distance service, as well as the provisioning of telecommunications equipment. From time to time, those subsidiaries may need or desire to share your Customer Proprietary Network Information (“CPNI”) with other Origin Exchange affiliates and/or with third parties involved in assisting with the offering of the services described above and also to enhance our ability to offer products and services tailored to you. Just as the applicable Origin Exchange subsidiary(s) is required to protect your CPNI, so too will these third parties. Under no circumstances will Origin Exchange and/or any Origin Exchange subsidiary sell your CPNI to third parties, or otherwise disclose your CPNI to third parties for marketing purposes in contravention of this Privacy Policy.

By way of clarification, CPNI comprises of: (i) information about the quantity, technical configuration, type, destination, location, and extent to which you use our communication-related services; and (ii) information contained on your telephone bill concerning the services you receive. That information, when matched to your name, address, and telephone number, is known as CPNI. Examples of CPNI include information typically available from telephone-related details on your monthly bill, technical information, type of service, current telephone charges, long distance and local service billing records, directory assistance charges, usage data, and calling patterns. CPNI does not include subscriber list information, aggregate information, or data not specific to a single customer.

You may examine and correct, if necessary, the CPNI-related personally identifiable information regarding you that is collected and maintained by us in our regular business records. In most cases, this information consists solely of billing and account information. We will correct our records if you make a reasonable showing that any such information we have collected about you is inaccurate. If you wish to examine these records, please contact us in writing at the address listed below. Please give us a reasonable period of time to locate and, if necessary, prepare the information for your review. You will only be permitted to examine records that contain personally identifiable information about your account and no other account.

You have the right to restrict our use of your CPNI by sending a request in writing to: Administrator Origin Exchange LLC, 8 The Green, Ste A, Dover, Delaware 19901. If you deny or restrict your approval for Origin Exchange to use your CPNI, you will suffer no effect, now or in the future, on the services provided to you other than our ability to provide you with, or otherwise notify you of, the customized offerings and enhanced services described above.

In the event Origin Exchange experiences a privacy breach and CPNI is disclosed to unauthorized persons, federal rules require that such breach be reported to law enforcement. Please be aware that we are not permitted by law to inform customers of the CPNI breach until at least seven (7) days after notification has been sent to law enforcement (which period may be extended if law enforcement shall advise us to withhold such information for a longer period of time).

Data Security

Origin Exchange implements data security systems and procedures to secure the information stored on Origin Exchange computer servers. Such systems and procedures reduce the risk of security breaches, but they do not provide absolute security. Therefore, Origin Exchange cannot guarantee that the Services are immune to unauthorized access to the information stored therein and to other information security risks.

Access To Personal Information

If your information changes, or if you no longer desire to use and access our Services, you may correct, update, or delete/deactivate your information by contacting us as defined in your service contract. Origin Exchange accepts requests for information where we are an information processor only from the applicable information controller. We will undertake to respond to your request within 30 days of Origin Exchange’s receipt thereof. Origin Exchange will make reasonable efforts to accommodate your requests.

We will retain your information for as long as required to provide you Services. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and to enforce our agreements.

Changes To This Privacy Policy

From time to time, Origin Exchange may change the terms of this policy. Changes will take effect once they are posted online and by accessing and/or using the Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. If you do not agree with any of the amended terms, you must avoid any further use of the Services offered by Origin Exchange.

Inquiries or Concerns?

You may contact Origin Exchange by using the ‘contact us’ feature that can be found at Contact Us, and we will do our best to provide a prompt response to your question. In addition, Origin Exchange’s Director, Corporate Compliance & Privacy and Data Protection Officer is responsible for overseeing compliance with this Privacy Policy. You can reach this officer by sending an email to privacy@originexchange.com.

In order to comply with the Privacy Shield Framework, Origin Exchange commits to the resolution of complaints about your privacy and our collection or use of your Information. We have also committed to resolve any complaints pursuant to the Privacy Shield Privacy Principles by European Union citizens, relating to this Privacy Policy and which cannot be resolved directly with Origin Exchange, through the JAMS EU-US Privacy Shield Dispute Resolution Framework as our Independent Recourse Mechanism (“IRM”). You can contact JAMS here for additional information or to file a complaint. The services of JAMS are provided to you at no cost.

If you have any questions or complaints regarding this Privacy Policy, please contact us as described above. We will investigate your question, respond to your inquiry, and attempt to resolve any concerns regarding your privacy question. If you do not receive acknowledgement of your complaint or, if your complaint is not satisfactorily addressed by Origin Exchange, then please contact JAMS, as described above.

As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means. We have registered with the United States Council for International Business to cover the operating costs of the EU DPAs’ dispute resolution panel. Origin Exchange is subject to the investigatory and enforcement powers of the FTC.