Privacy Policy

This Privacy Policy describes how Maxselle Media Inc., operating as Ohmy (“Ohmy,” “we,” “us” or “our“), collects, uses, discloses and otherwise processes personal information in connection with this website, our communications and the services we provide to our clients. We are committed to handling personal information responsibly, transparently and in accordance with applicable privacy laws.

1. Scope and our role

This Privacy Policy applies to personal information we collect through our website and any other website or page that links to this Privacy Policy, our emails, events and business development activities, and the provision of our services (collectively, the “Services“).

Depending on the context, we process personal information in one of two capacities:

• As a controller. We determine the purposes and means of processing personal information relating to website visitors, prospective clients, client representatives, business partners, suppliers and job applicants. This Privacy Policy governs that processing.
• As a service provider or processor. When we process personal information on behalf of a client in the course of delivering the Services (for example, customer lists, contact records, campaign data or website form submissions), we do so on the client’s documented instructions and in accordance with our agreement with that client. In those cases, the client’s privacy policy governs, and individuals should direct inquiries to the relevant client. We will assist our clients in responding to such inquiries as required.

2. Personal information we collect

Information you provide to us. We collect personal information that you provide directly, including:

• contact and professional details, such as your name, business email address, telephone number, employer and job title;
• the content of your communications with us, including inquiries, form submissions, meeting requests, project briefs and feedback;
• materials provided to us in connection with the Services, such as brand assets, documents, data and access credentials to business accounts;
• billing and payment information (payment card details are processed by our third-party payment processors and are not stored by us); and
• information submitted in connection with employment applications.

Meetings and calls. With notice to participants, we may record or transcribe calls and meetings for record-keeping, quality and service delivery purposes. Participants may ask that a meeting not be recorded.

Information collected automatically. When you visit our website or interact with our emails, we and our service providers may automatically collect technical and usage information, such as IP address, approximate location, browser and device characteristics, pages viewed, referring URLs and interaction data, using cookies and similar technologies (see Section 6).

Information from other sources. We may obtain business contact information from publicly available sources (such as company websites, professional networking platforms and industry directories), business data providers, referral sources and partners, and aggregated reporting from advertising and analytics platforms.

Sensitive information. We do not seek to collect health information, government-issued identification numbers or other sensitive personal information through our website or business development activities. Please do not provide such information unless we have agreed in writing on how it will be handled.

3. How we use personal information

We use personal information for the following purposes:

• Providing the Services: to respond to inquiries, perform our contractual obligations, manage client relationships and accounts, and process invoices and payments;
• Communications: to send service-related communications and, in accordance with applicable law, newsletters, updates and business-to-business marketing communications;
• Improvement and development: to operate, evaluate and improve our website, Services, methodologies and internal systems, using de-identified or aggregated information where practicable. We do not use one client’s confidential information in the delivery of services to another client;
• Analytics and advertising: to understand how our website is used and to deliver and measure our advertising, subject to your consent where required by law;
• Security and compliance: to protect the security and integrity of our Services, detect and prevent fraud and misuse, comply with legal and regulatory obligations, and establish, exercise or defend legal claims; and
• Recruitment: to evaluate applications and communicate with candidates.

We will not use personal information for purposes materially different from those described in this Privacy Policy without providing notice and, where required, obtaining your consent.

4. Technology and artificial intelligence

We use technology, including artificial intelligence tools, to support research, analysis, content development and the efficient delivery of our Services. In doing so:

• personal information may be processed by technology providers acting as our service providers, subject to contractual and technical safeguards appropriate to the information involved;
• we take reasonable measures to ensure that information we submit to such providers is not used to train their general-purpose models;
• work product generated with the assistance of these tools is directed and reviewed by our personnel;
• information relating to each client is maintained separately and is not used in work for other clients; and
• we do not make decisions about individuals based solely on automated processing that produce legal or similarly significant effects.

5. How we disclose personal information

We disclose personal information only as described in this Privacy Policy, including to:

• Service providers that perform services on our behalf, such as hosting, cloud storage, software, communications, customer relationship management, analytics, scheduling and payment processing. Service providers are contractually required to protect personal information and to use it only to provide services to us;
• Specialists and subcontractors engaged to support client engagements, subject to confidentiality obligations;
• Advertising and analytics partners through cookies and similar technologies, as described in Section 6;
• Legal authorities and other parties where required by law or legal process, or where reasonably necessary to protect the rights, property or safety of Ohmy, our clients or others;
• Parties to a business transaction, such as a merger, acquisition, financing or sale of assets, subject to appropriate confidentiality protections; and
• Other parties with your consent or at your direction.

We do not sell personal information for monetary consideration. Certain U.S. state laws may treat the use of advertising cookies as a “sale” or “sharing” of personal information. You may opt out of such activities as described in Sections 6 and 10.

6. Cookies and similar technologies

We use the following categories of cookies and similar technologies:

• Strictly necessary: required for the operation and security of the website;
• Analytics: used to understand how visitors use the website so that we can improve it; and
• Marketing: used to deliver and measure our advertising on third-party websites and platforms.

Where consent is required by law (including in the European Economic Area, the United Kingdom and Quebec), analytics and marketing cookies are used only with your consent. You may change your preferences at any time through our cookie settings or your browser. Where required by applicable law, we recognize Global Privacy Control signals as a valid opt-out request.

7. Legal bases for processing (EEA and UK)

If you are located in the European Economic Area or the United Kingdom, we process personal information on the following legal bases:

• Performance of a contract: to provide the Services requested by you or your organization;
• Legitimate interests: to operate and improve our business, market our Services to businesses, maintain security and manage recruitment, where those interests are not overridden by your rights and interests;
• Consent: for non-essential cookies and certain marketing communications, which you may withdraw at any time; and
• Legal obligation: to comply with tax, accounting and other legal requirements.

8. International transfers

Ohmy is based in Canada. We and our personnel, subcontractors and service providers may process personal information in Canada, the United States and other jurisdictions. As a result, personal information may be stored or accessed outside your jurisdiction, where privacy laws may differ and where it may be accessible to local authorities in accordance with local law.

Where we transfer personal information from the European Economic Area or the United Kingdom, we rely on adequacy decisions or appropriate safeguards, such as the European Commission’s Standard Contractual Clauses and the UK International Data Transfer Addendum.

9. Retention

We retain personal information for as long as necessary to fulfil the purposes described in this Privacy Policy, including to provide the Services, maintain business records, and comply with legal, tax, accounting and regulatory requirements. When personal information is no longer required, we delete or anonymize it in accordance with our internal practices and applicable law.

Where you opt out of marketing communications, we retain limited information to ensure your preference is respected. Personal information processed on behalf of clients is retained in accordance with our agreement with the relevant client.

10. Your rights

Subject to applicable law, you may have the right to:

• request access to, and a copy of, your personal information;
• request correction of inaccurate or incomplete personal information;
• request deletion of your personal information;
• withdraw your consent, where processing is based on consent; and
• opt out of marketing communications at any time, using the unsubscribe link in our emails or by contacting us.

Canada. Under applicable Canadian privacy laws, you may also request information about how your personal information has been used and disclosed. Residents of Quebec may also request that computerized personal information be communicated in a structured, commonly used technological format. You may file a complaint with the Office of the Privacy Commissioner of Canada or, in Quebec, the Commission d’accès à l’information.

EEA and UK. You may also have the right to restrict or object to processing, including the right to object at any time to direct marketing, and the right to data portability. You may lodge a complaint with your local supervisory authority.

United States. Depending on your state of residence, you may also have the right to opt out of targeted advertising, the sale of personal information and certain profiling, and to appeal our decision regarding your request. We will not discriminate against you for exercising your rights. You may designate an authorized agent to submit a request on your behalf, subject to verification.

Submitting a request. To exercise your rights, contact us at privacy@meetohmy.com. We will verify your identity before responding and will respond within the time required by applicable law. Where we process your information on behalf of a client, we will refer your request to that client.

11. Security

We maintain administrative, technical and organizational safeguards designed to protect personal information against loss, theft and unauthorized access, use, disclosure, copying or modification, appropriate to the sensitivity of the information. These include access controls, multi-factor authentication, encryption in transit, the principle of least privilege, service provider due diligence and confidentiality obligations for our personnel.

No method of transmission or storage is completely secure. In the event of a breach of security safeguards involving personal information, we will notify affected individuals and the relevant authorities as required by applicable law.

12. Health information

Our website and business development activities are not designed to collect personal health information. Where a client engagement requires us to process personal health information, we do so only under a written agreement that sets out the applicable safeguards, such as a Business Associate Agreement under HIPAA or a data processing agreement, and only within the systems permitted by that agreement.

13. Children

Our Services are intended for businesses and professionals and are not directed to children. We do not knowingly collect personal information from individuals under the age of 16. If you believe a child has provided us with personal information, please contact us and we will delete it.

14. Third-party websites

Our website may contain links to third-party websites and services. We are not responsible for the privacy practices of those third parties, and we encourage you to review their privacy policies.

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The updated version will be posted on this page with a revised “Last updated” date. Where changes are material, we will provide additional notice as appropriate.

16. Contact us

Our Privacy Officer is accountable for our compliance with this Privacy Policy. Questions, requests and complaints may be directed to:

Privacy Officer: Bulat Gazizoff
Email: privacy@meetohmy.com
Mail: Maxselle Media Inc., operating as Ohmy, 1 Bloor Street East, Toronto, Ontario, Canada