Privacy Policy

THE OOLA GROUP PRIVACY POLICY

Last updated: March 2, 2023

This is the privacy policy (“Privacy Policy”) that governs how The OOLA Group, LLC, a Missouri limited liability company (“ The OOLA Group”, “we”, “our” or “us”), uses Personal Data (defined below) that we collect, receive and store about individuals in connection with the use of our website: https://www.oola.com (together with its sub-domains, content and services, a “Site”).

You may choose whether or not to provide or disclose Personal Data in connection with your use of our Site. If you choose not to provide the Personal Data we request, you may still visit and use parts of our Site, but may be unable to access or use certain features, options, programs, and services. Our Site may contain links to third-party websites and services that are not owned or controlled by The OOLA Group. We are not responsible for the privacy practices or the content of third party websites, services and advertisements, and you visit them at your own risk.

1. Introduction

We are committed to respecting privacy and recognize the need for appropriate protection and management of any Personal Data that is shared with us as part of using our Site. As used in this Privacy Policy, “Personal Data” means any information that may be used, either alone or in combination with other information, to personally identify an individual.

2. Changes to this Privacy Policy.

We reserve the right, at our discretion, to change the terms of this Privacy Policy at any time. You can see when this Privacy Policy was last updated by reviewing the “Last Updated” legend on the top of this page. We may provide you with notice of material changes to the Privacy Policy as appropriate under the circumstances. UNLESS OTHERWISE INDICATED, ANY CHANGES TO THIS PRIVACY POLICY WILL APPLY IMMEDIATELY UPON POSTING TO THE SITE.

3. Information Collected.

We may receive and/or collect Personal Data in the following ways:

3.1. Personal Data You Provide To Us On Our Site. If you send us a “Contact Us” request or feedback, or in connection with creating a job profile on our Site, or when you download any of our content, you may be required to provide us with certain information that may constitute Personal Data, such as:

Your name;
Email address;
Phone Number;
Address;
Profile photo; and
Communications you send to us.

3.2. Personal Data You Provide To Third Parties On Our Site. Please note that we use certain third party service providers on our Site to enhance your experience or deliver certain services. These providers may collect Personal Data in performing their services and/or functions on our Site. For example, we use the following third party service providers for the services identified:

Google Analytics to track user behavior and content consumption on the Site. To learn more about the privacy practices of Google Analytics, please review https://www.google.com/policies/technologies/product-privacy/
Facebook Business Tools, including pixels which use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet, and use that information to provide measurement services and target ads. To learn more about the privacy practices of Facebook, please review https://www.facebook.com/privacy/explanation

3.3. Information Collected Automatically. Certain information on our Site is collected automatically by means of various software tools. We have a legitimate interest in using such information to assist in log-in, systems administration purposes, information security and abuse prevention, to track user trends, and to analyze the effectiveness of our Site. Alone or in combination with other information, such automatically collected information may constitute Personal Data. Some of our service providers (described in Section 5, below) may use cookies or other methods to gather information regarding your use of our Site. Such third parties may use these cookies or other tracking methods for their own purposes by relating information about your use of our Site with any of your Personal Data that they may have. The use of such information by a third party depends on the privacy policy of that third party.

a) Log Files On Our Site. The information inside the log files includes internet protocol (“IP”) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us.

b) Cookies. We use cookies to make interactions with our Site easy and meaningful. When you visit our Site, our servers may send a cookie to your computer. Standing alone, cookies do not personally identify you; they merely recognize your web browser. Unless you choose to identify yourself to us, either by responding to a promotional offer, opening an account, or filling out a web form, you remain anonymous to us.

We may use cookies that are session-based or persistent. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. Please note that if you disable your web browser’s ability to accept cookies, you will be able to navigate our Site, but you may not be able to successfully use all of the features of our Site
The following sets out how we may use different categories of cookies and your options for managing cookies’ settings:

Type of Cookies	Description	Managing Settings
Required cookies	Required cookies enable you to navigate our Site and use its features, such as accessing secure areas of our Site and using our services. If you have chosen to identify yourself to us, we use cookies containing encrypted information to allow us to uniquely identify you. Each time you log into our Site, a cookie containing an encrypted, unique identifier that is tied to your account is placed on your browser. These cookies allow us to uniquely identify you when you are logged into our Site and to process your online transactions and requests.	Because required cookies are essential to operate our Site, there is no option to opt out of these cookies.
Performance cookies	These cookies collect information about how you use our Site, including which pages you go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies you. All information these cookies collect is aggregated and anonymous. It is only used to improve how our Site functions and performs. From time-to-time, we may engage third parties to track and analyze usage and volume statistical information from individuals who visit our Site. We may also utilize Flash cookies for these purposes.	To learn how to opt out of performance cookies using your browser settings click here. To learn how to manage privacy and storage settings for Flash cookies click here.
Functionality cookies	Functionality cookies allow our Site to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of our Site after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. We may use local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on our Site to personalize your visit.	To learn how to opt out of functionality cookies using your browser settings click here. To learn how to manage privacy and storage settings for Flash cookies click here.
Targeting or Advertising cookies	From time-to-time, we may engage third parties to track and analyze usage and volume statistical information from individuals who visit our Site. We sometimes use cookies delivered by third parties to track the performance of our advertisements. For example, these cookies remember which browsers have visited our Site. The information provided to third parties does not include Personal Data, but this information may be re-associated with Personal Data after we receive it. By way of example, as you browse our Site, advertising cookies may be placed on your computer so that we can understand what you are interested in. Our advertising partners then enable us to present you with retargeted advertising on other sites based on your previous interaction with our Site. We also contract with third-party advertising networks and similar partners that collect IP addresses and other information from web beacons (see below) on our Site, from emails, and on third-party sites. Ad networks follow your online activities over time by collecting web Site Navigational Information through automated means, including through the use of cookies. They use this information to provide advertisements about products and services tailored to your interests. You may see these advertisements on other websites. This process also helps us manage and track the effectiveness of our marketing efforts. Third parties, with whom we partner to provide certain features on our Site or to display advertising based upon your web browsing activity, use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored.	To learn more about these and other advertising networks and their opt out instructions, click here. To learn how to manage privacy and storage settings for Flash cookies click here.

c) Other Tracking Technologies. When you visit our Site, we may collect your IP addresses to track and aggregate data. For example, we may use IP addresses to monitor the regions from which you navigate our Sites.

We may also use web beacons alone or in conjunction with cookies to compile information about your usage of our Site and interaction with emails from us. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular site tied to the web beacon. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to our Site. We may use web beacons to operate and improve our Site and email communications.

When you use our website, we share information that we collect from you, such as your email (in hashed form), IP address or information about your browser or operating system, with our identity partners/service providers, including LiveRamp Inc. LiveRamp returns an online identification code that we may store in our first-party cookie for our use in online, in-app, and cross-channel advertising and it may be shared with advertising companies to enable interest-based and targeted advertising. To opt out of this use, please see https://optout.liveramp.com/opt_out.

d) Analytics and Ad-Tracking Tools.We use various industry standard analytics tools and services on our Site for tracking, such as Google Analytics. For more information on Google Analytics’ processing of Personal Data, please see http://www.google.com/policies/privacy/partners/.

We use advertising service providers to deliver interest-based advertising to you. Our service providers allow for certain opt-out choices, either directly through a browser plug-in or through collective services such as the Digital Advertising Alliance and the National Advertising Initiative. Our service providers have provided the following opt-out options:

Visit	Select
Digital Advertising Alliance	Amazon Ad System, AOL Advertising, AppNexus, Facebook, Google Inc, Index Exchange, Netseer, OpenX, Playwire Media, Rubicon Project, Sovrn, or Yieldmo
National Advertising Initiative	AOL Advertising, AppNexus, Google Inc, Index Exchange, Netseer, Playwire Media, Rubicon Project, or Yieldmo
Google	Install your browser plugin
TripleLift	Opt-out of tailored advertising from Triplelift

4. The Purposes For Which We Use Personal Data.

If you submit or we collect Personal Data through our Site, then such Personal Data may be used in the following ways: (i) to provide, analyze, administer, and improve our Site and services, (ii) to contact you in connection with our Site and certain services, notifications, events, programs or offerings that you may have registered for, (iii) to send you updates and promotional materials that you have registered for, (iv) to identify and authenticate your access to the parts of our Site and services that you are authorized to access; (v) for recruiting and human resources administration purposes, and (vi) to protect our rights and/or our property and to ensure the technical functionality and security of our Site.

5. How We Disclose Personal Data.

We do not sell, lease, rent or otherwise disclose the Personal Data collected from our Site to third parties unless otherwise stated below or with your consent.

5.1. Our Third Party Providers. We transfer Personal Data to our third party service providers to perform tasks on our behalf and to assist us in providing our Site. Such information may be transferred to other countries around the world. We use commercially reasonable efforts to only engage or interact with third party service providers and partners that post a privacy policy governing their processing of Personal Data. Notwithstanding the foregoing, we will comply with applicable laws regarding Personal Data transfers as well as any transfer restriction that is specified in an agreement between The OOLA Group and a customer.

5.2 Business Partners. From time to time, we may partner with other companies to jointly offer products or services. If you purchase or specifically express interest in a jointly-offered product or service from us, we may share Personal Data collected in connection with your purchase or expression of interest with our joint promotion partner(s). We do not control our business partners’ use of Personal Data we collect, and their use of the information will be in accordance with their own privacy policies. We do not share Personal Data with business partners unless you specifically opt in to such sharing via an event registration form. If you do not wish for your Personal Data to be shared in this manner, you may choose not to opt in via event registration forms.

5.3. In the Event of Merger, Sale, or Change of Control. We may transfer or assign this Privacy Policy and any Personal Data to a third party entity that acquires or is merged with as part of a merger, acquisition, sale, or other change of control.

5.4. Other Disclosures. We may disclose Personal Data about you if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our terms of use, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of The OOLA Group, our users, or the public.

6. Retention of Personal Data.

We reserve the right to retain any Personal Data as long as the Personal Data are needed to: (i) fulfill the purposes that are described in Section 4 (The Purposes For Which We Use Personal Data), and (ii) comply with applicable law.

7. Your Rights.

7.1 Personal Data. If you have a job seeker account on our Site, we provide access to—and the ability to edit or delete—certain categories of Personal Data through the account.

If you would like to access, amend, erase, export (i.e., data portability), or object to or restrict the processing of Personal Data collected via our Site, you may submit a request to info@ theoolagroup.com or write to us at:

The OOLA Group
6642 Clayton Road #363
St. Louis, MO 63117

We will promptly review all such requests in accordance with applicable laws.

Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Data about you. We encourage you to first reach out to us at info@ theoolagroup.com, so we have an opportunity to address your concerns directly before you do so.

7.2. Opting-Out of Promotional Emails. You may choose not to receive future promotional or advertising emails from us by selecting an unsubscribe link at the bottom of each email that you receive from us, or by responding to the emails directly and requesting removal if such a link is not available. Additionally, you may send a request specifying your communications preferences to info@ theoolagroup.com. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any “Contact Us” request as well as administrative, maintenance and operational emails.

8. Data Security.

The security of Personal Data is important to us. We follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Data, we cannot guarantee its absolute security.

9. Children’s Privacy.

Our Site is not intended for children under the age of 13. Accordingly, we do not intend to collect Personal Data from anyone we know to be under 13 years of age.

10. How We Respond to Do Not Track Signals.

At this time, The OOLA Group is unable to universally respond to “Do Not Track” or other “opt-out” mechanisms that have been activated by a user through their web browser, and except as otherwise provided herein, does not alter its policies if a user activates such mechanism.

11. Advertising

This Site is affiliated with Freestar for the purposes of placing advertising on the Site, and Freestar will collect and use certain data for advertising purposes. To learn more about Freestar’s data usage, click here: https://freestar.com/privacy-policy/.

12. Your California Privacy Rights.

If you are a California resident and have provided Personal Data to The OOLA Group through the Site, you are entitled by law to request certain information regarding any disclosure that may have been made by The OOLA Group to third parties of Personal Data for their direct marketing purposes. To make such a request, send an email to info@ theoolagroup.com specifying that you seek your “California Customer Choice Privacy Notice.” Please allow thirty (30) days for a response. The OOLA Group is required to respond to only one request per customer each year, and is not required to respond to requests made by means other than through the above email address. We will not share Personal Data about you with third parties for their direct marketing purposes if you request that we do not do so. If you would like more information about not having your information used by third parties, or if you would like to make such an opt-out request, you may send us an email at info@ theoolagroup.com. For your additional rights under the California Consumer Privacy Act (“CCPA”), please see “Special information for California consumers.” You may also request to opt-out of an advertiser’s use of cookies by visiting the Network Advertising Initiative or the Digital Advertising Alliance. You may request to opt-out of Google’s use of cookies by visiting www.google.com/ads/preferences. All applicable terms on these websites will apply to your request to opt-out in addition to this Privacy Policy. When contacting us, please indicate your name, address, email address, and what Personal Data you do not want us to share with third parties for their direct marketing purposes. Please note that there is no charge for controlling the sharing of Personal Data or for processing this request.

13. Contacting Us

Any comments, concerns, complaints, or questions regarding our Privacy Policy may be addressed to info@ theoolagroup.com.

Special Information for California consumers

Last Revised: December 16, 2019

1. Introduction.

If you are a California consumer, as such term is used in the California Consumer Privacy Act (“CCPA”), you may have certain rights to make requests relating to your personal information.

2. Your Privacy Rights.

Under California law, California consumers have the following rights with respect to their personal information:

Privacy Right	Description
Notice	You have the right to be notified of what categories of personal information will be collected at or before the point of collection and the purposes for which they will be used and shared.
Access	You have the right to request information on the categories of personal information that we collected in the previous twelve (12) months, the categories of sources from which the personal information was collected, the specific pieces of personal information we have collected about you, and the business purposes for which such personal information is collected and shared. You also have the right to request information on the categories of personal information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your personal information.
Data Portability	You have the right to receive the personal information you have previously provided to us.
Erasure	You have the right to request to have your personal information deleted from our servers and we will direct our service providers to do the same. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required to retain your personal information for one or more of the following categories of purposes: (1) to complete a transaction for which the personal information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law; (4) to otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Opt Out of a Sale	You have a right to opt-out of the sale of personal information. We do not sell information that you voluntarily provide us, such as your name, address, telephone number or email address or information that you provide to us in connection with a customer relationship. However, as mentioned above, we share online information – such as your IP address, device and browser type – with companies such as Google and Facebook to improve your experience on our website and better serve you with advertising and content such as articles. To opt out of this “sale” of personal information, please see Section 3.3(d), above.

3. How to Exercise Your Rights.

If you would like to exercise your rights listed above, please send an email to info@ theoolagroup.com or send a request to The OOLA Group, attn: CCPA notices, 6642 Clayton Road #363, St. Louis, MO 63117. If you choose to exercise either of these rights, we will use reasonable methods to verify your identity. Additionally, you may designate an authorized agent to make requests on your behalf.

While we take measures to ensure that those responsible for receiving and responding to your request are informed of your rights and how to help you exercise those rights, when contacting us to exercise your rights, we ask you to please adhere to the following guidelines:

• Tell Us Which Right You Are Exercising: Specify which right you want to exercise and the personal information to which your request relates (if not to you). If you are acting on behalf of another consumer, please clearly indicate this fact and your authority to act on such consumer’s behalf.

• Help Us Verify Your Identity: Provide us with information to verify your identify. Please note that if we cannot initially verify your identity, we may request additional information to complete the verification process. Any personal information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.

• Direct Our Response Delivery: Please provide us with an e-mail or mailing address through which we can provide our response. If you make the request by email, unless otherwise requested, we will assume that we can respond to the email address from which you made the request.

You have a right not to receive discriminatory treatment by any business when you exercise of your California privacy rights.