PRIVACY POLICY

Last updated March 31, 2025

Thank you for choosing to be part of our community at OCM Partners Group LLC (“OCM Partners Group”, “OCM Partners”, “Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this Privacy Policy, or our practices with regards to your personal information, please contact us at hello@ocmpartners.com.

When you visit our website https://ocmpartners.com (the “Website“), and more generally, use any of our services (the “Services“, which include the Website), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this Privacy Policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our Services immediately.

This Privacy Policy applies to all information collected through our Services (which, as described above, includes our Website), as well as any related services, sales, marketing or events.

Please read this Privacy Policy carefully as it will help you understand what we do with the information that we collect.

WHAT PERSONAL INFORMATION DO WE COLLECT?

We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

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Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Yes
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	No
D Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes
Geolocation data.	Physical location or movements.	Yes
Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	Yes
Professional or employment-related information.	Current or past job history or performance evaluations	Yes
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes
Sensitive personal information	Personal information that reveals: (A) A person’s social security, driver’s license, state identification card, or passport number. (B) A person’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. (C) A person’s precise geolocation. (D) A person’s racial or ethnic origin, religious or philosophical beliefs, or union membership. (E) The contents of a person’s mail, email, and text messages unless the business is the intended recipient of the communication. (F) A person’s genetic data. The processing of biometric information for the purpose of uniquely identifying a consumer. Personal information collected and analyzed concerning a consumer’s health. Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.	Yes

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The personal information that we collect depends on the context of your interactions with us and our Services, the choices you make and the products and features you use. The information we collect is used to provide and improve our services, communicate with users, send updates, and ensure compliance with applicable laws. This information is not shared with third parties for marketing purposes.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Anonymized, Aggregated, or De-Identified Personal Information

We may also anonymize, aggregate or de-identify personal information so the end-product does not identify you or any other individual. For example, we may use this information to generate norms by industry, geography, level, etc., enable us to understand where our services are being utilized, conduct ongoing validation studies, compile reports, and improve the services. Such aggregated, anonymized or de-identified information is not considered personal information for purposes of this Privacy Policy and we may use it for any purpose.

Information automatically collected

We automatically collect certain information when you visit, use or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about who and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.

HOW YOUR PERSONAL INFORMATION IS COLLECTED

We collect most of this personal information directly from you – in person, by telephone, text or email and via our Website when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Website or otherwise when you contact us. However, we may also collect information from:

From publicly accessible sources;
Directly from a third party (e.g., joint marketing partners, affiliate programs, data providers);
From a third party with your consent (e.g., your social media accounts including Google, Facebook, Twitter, LinkedIn);
From cookies on our Website; and
Via our IT systems, including automated monitoring of our Websites and other technical systems, such as our computer networks and connections, communications systems, and email and instant messaging systems.

This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted advertising and event promotion.

HOW AND WHY WE USE YOUR PERSONAL INFORMATION

Under data protection law, we can only use your personal information if we have a proper reason for doing so. We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal and regulatory obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

A legitimate business interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

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What we use your personal information for

Our reasons

To provide our Services to you..

If you choose to link your account with us to a third-party account (such as your Google, LinkedIn or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process.

We may use your information for the purposes of managing your account and keeping it in working order.

We may use your information to administer prize draws and competitions when you elect to participate in our competitions.

We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

To enable user-to-user communications with each user’s consent.

For the performance of our contract with you or to take steps at your request before entering into a contract.

To prevent and detect fraud against you or OCM Partners Group and as part of our efforts to keep our Website safe and secure.

For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you.

Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. if we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

To comply with our legal and regulatory obligations.

Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies.

To comply with our legal and regulatory obligations.

Ensuring business policies are adhered to, e.g. policies covering security and internet use, and to enforce our terms, conditions and other applicable policies.

For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you.

Operational reasons, such as improving efficiency, training and quality control.

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price.

Ensuring the confidentiality of commercially sensitive information.

For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information.

To comply with our legal and regulatory obligations.

Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Website, products, marketing and your experience.

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price.

Preventing unauthorized access and modifications to systems.

For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you.

To comply with our legal and regulatory obligations.

Updating and enhancing customer records.

For the performance of our contract with you or to take steps at your request before entering into a contract.

To comply with our legal and regulatory obligations.

For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products.

Ensuring safe working practices, staff administration and assessments

To comply with our legal and regulatory obligations.

For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you.

Marketing our Services and those of selected third parties to:

existing and former customers;
third parties who have previously expressed an interest in our services;
third parties with whom we have had no previous dealings.

To send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

To post testimonials. Prior to posting a testimonial, we will obtain your consent to use your name and the consent of the testimonial. If you wish to update, or delete your testimonial, please contact us at hello@ocmpartners.com and be sure to include your name, testimonial location, and contact information.

To request feedback and to contact you about your use of our Website.

To send you marketing and promotional communications, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Services, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the “PROMOTIONAL COMMUNICATIONS” below).

For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers.

External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts.

For our legitimate interests or those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards.

To comply with our legal and regulatory obligations.

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‍4. PROMOTIONAL COMMUNICATIONS

We may use your personal information to send you updates (by email, text message) about our Services, including exclusive offers, promotions or new products and/or services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “HOW AND WHY WE USE YOUR PERSONAL INFORMATION”).

You have the right to opt out of receiving promotional communications at any time by:

Contacting us at hello@ocmpartners.com; or
Using the “unsubscribe” link in emails or “STOP” number in texts

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We respect your privacy, and your mobile phone contact information will not be shared or sold to third parties/affiliates for marketing/promotional purposes.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business. Please note that even if you opt out of receiving promotional communications, you may still receive communications related to the OCM Partners Group’s oversight activities or otherwise as required by law.

WHO WILL YOUR INFORMATION BE SHARED WITH?

We do not share personal information or data with third parties or affiliates, except as necessary to provide our services or as required by law. We do not sell your personal information to third parties for marketing purposes.

We routinely share personal information with the following categories of third parties:

Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect data on our behalf about how you interact with our Website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit or use the Website. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.

All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details provided in the section below titled “HOW CAN YOU CONTACT US ABOUT THIS POLICY?“.

We only allow third parties to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We have contracts in place with our data processors, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

Additionally, we may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

Cookies and Other Tracking Technologies

Like many businesses, we also collect information through cookies and similar technologies.

Cookies are small text files of information stored by the Internet browser on your computer’s hard drive. We may use these cookies to collect browsing data on our Site to keep track of your preferences and profile information and to collect general usage and volume statistical information. Our cookies do not collect personal or confidential information and are not spyware.

Our Website contains electronic images known as web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our Website is used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications. We use a third party to gather information about how you and others use our Website. For example, we will know how many users access a specific page and which links they clicked on. We use this aggregated information to understand and optimize how our Website is used.

Targeted Advertising (also known as online behavioral advertising) uses information collected on an individual’s web browsing behavior such as the pages they have visited or the searches they have made. Third parties collect this information by placing or accessing cookies in your browser when you visit this Website, or other, websites. If you would like to learn more about the third party advertisers that may be aware of the fact that you visit this Website, and to understand your choices about having such advertisers’ cookies turned off, please visit www.networkadvertising.org.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic usage and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system configuration information.
Location Data. We collect information such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type of settings of the device you use to access the Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Locations settings on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy. Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website. To opt-out of interest-based advertising by advertisers on our Website visit http://www.aboutads.info/choices/.

WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

The Website may contain advertisements and links from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. When you click on a link to any other website or location, you will leave our Website and go to another site, and another entity may collect personal data or anonymous data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this Privacy Policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Website. As such, we urge that you exercise caution before providing them with your personal information. You should review the policies of such third parties and contact them directly to respond to your questions.

The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

You should contact the site administrator for such third party website if you have any complaints, claims, concerns or questions regarding such third party website or its privacy practices.

HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements, to respond to any questions, complaints or claims made by you or on your behalf, and to show that we treated you fairly). Different retention periods apply for different types of personal information.

For regulatory compliance purposes, we will keep the categories of personal information identified in the Section titled “WHAT PERSONAL INFORMATION DO WE COLLECT”, above, for a maximum of 7 years.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. We endeavor to protect the personal information we receive, gather and store, by such means as password protection, firewalls and other means. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also require that third party service providers acting on our behalf or with whom we share your information also provide appropriate security measures in accordance with industry standards. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.

We will maintain a record of every breach of security safeguards involving personal information under our control. We will notify you of any breach of our security safeguards involving your personal information if it is reasonable in the circumstances to believe that the breach creates a real risk of significant harm to you.

DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at hello@ocmpartners.com. Please visit the FTC’s website at www.ftc.gov for tips on protecting children’s privacy online.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

WHERE YOUR PERSONAL INFORMATION IS HELD.

Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: “Who Will Your Information Be Shared With?”).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.

TRANSFERRING YOUR PERSONAL INFORMATION OUT OF THE EEA.

To deliver Services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

With our offices outside the EEA;
With your and our service providers located outside the EEA;
If you are based outside the EEA; or
Where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under European and UK data protection law.

These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. In particular, you are advised that the United States of America uses a sectoral model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. If you are located outside the United States, we will only transfer your personal information if:

you provide your explicit consent;
the country to which the personal information will be transferred has been granted an appropriate adequacy decision by the local supervisory authority; or
we have put in place appropriate safeguards in respect of the transfer, for example we have entered into the appropriate standard contractual clauses and required additional safeguards with the recipient, or the recipient is a party to binding corporate rules approved by a supervisory authority.

OCM Partners Group is headquartered in the United States and utilizes service providers both in the United States and throughout the world. As such, OCM Partners Group and our service providers may transfer your personal information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.

Where the laws of your country allow you to do so, by using the Website or the Services, you consent and authorize OCM Partners Group to transfer, store, and use all such information in the United States of America and any other country where we operate which may not offer an equivalent level of protection to that required in the country where you reside and to the processing of that information by us on its servers located in the United States of America as described in this Privacy Policy. If you do not want your personal information transferred to the United States of America and any other country where we operate, please do not submit any information to us or use our Services.

If you would like further information, please contact us (see “How You Can Contact Us About This Policy” below).

CANADA’S PERSONAL INFORMATION PROTECTION AND ELECTRONIC DOCUMENTS ACT

You may have the following rights under Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA):

You have a right to know how your information will be used. We will explain why we need your information before or when we collect it, if the purpose is not already clear.
We will collect personal information only for the purposes we’ve identified or for the primary uses described above. We shall collect information by fair and lawful means only.
We will not use or disclose your personal information other than for the purposes for which it was collected unless we receive your consent or unless we are required or permitted to by law.
We will keep your personal information only for as long as it needs to for the purposes identified above, as required by law, or as necessary to resolve any disputes you may have concerning our Services. We will follow internally set guidelines and use care in the disposal, destruction, or de-identification of personal information to prevent unauthorized parties from gaining access to such information.
We will maintain accurate, complete and up-to-date personal information as required for the identified purposes associated with its collection. Please let us know if your contact or other personal information changes.
Upon your written request, and subject to exceptions as permitted or mandated by law, we will inform you of the existence, use and disclosure of your personal information and will give you access to that information. You may challenge the accuracy and completeness of your information and have it amended as appropriate.

WHAT ARE YOUR PRIVACY RIGHTS UNDER GDPR?

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws.

Right to Access	The right to be provided with a copy of your personal information (the right of access)
Right to Rectification	The right to require us to correct any mistakes in your personal information
Right to be Forgotten	The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing	The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Right to Data Portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object	The right to object: at any time to your personal information being processed for direct marketing (including profiling); in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Right Not to be Subject to Automated Individual Decision-Making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

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For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.

WHAT ARE YOUR PRIVACY RIGHTS UNDER CCPA AND CPRA?

If you are a California resident, you have may have the following rights under the California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CPRA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

Disclosure of Personal Information We Collect About You	You have the right to know: The categories of personal information we have collected about you; The categories of sources from which the personal information is collected; Our business or commercial purpose for collecting or selling personal information; The categories of third parties with whom we share personal information, if any; and The specific pieces of personal information we have collected about you.
Personal Information Sold, Shared, Disclosed or Used for a Business Purpose	In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold; and The categories of personal information that we disclosed about you for a business purpose. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale or disclosure of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link here.
Right to Limit Use and Disclosure of Sensitive Personal Information.	You have the right to opt-out of the use and disclosure of your sensitive personal information for anything other than supplying requested goods or services. To limit the use and disclosure of your personal information, click on the Limit the Use of My Sensitive Personal Information link here.
Right to Correction	You have the right to request correction of inaccurate personal information maintained by us about you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
Right to Deletion	Subject to certain exceptions, on receipt of a verifiable request from you, we will: Delete your personal information from our records; and Direct any service providers to delete your personal information from their records.
Protection Against Discrimination	You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: Deny goods or services to you; Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of goods or services to you; or Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of [goods and/or services] to you, if that difference is reasonably related to the value provided to our business by your personal information.

OCM Partners Group has disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

Identifiers, such as contact details, like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name.
Personal information such as your name, contact information, education, employment, employment history and financial information.
Characteristics of protected classifications under California or federal law, such as gender or date of birth.
Commercial information, such as transaction information, purchase history, financial details and payment information.
Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements.
Geolocation data, such as device location.
Audio, electronic, visual and similar information, such as images and audio, video or call recordings created in connection with our business activities.
Professional or employment-related information, such as business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us.
Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under “WHO WILL YOUR INFORMATION BE SHARED WITH?”.

OCM Partners Group has sold the following categories of personal information to third parties in the preceding twelve (12) months:

Personal information such as your name, contact information, education, employment, employment history and financial information.
Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

HOW TO EXERCISE YOUR RIGHTS

If you would like to exercise any of your rights as described in this Privacy Policy, please:

Email us at hello@ocmpartners.com.

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact directly by Website or email, you will need to provide us with:

Enough information to identify you; and
A description of what right you want to exercise and the information to which your request relates.

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate. We will respond to your request within 30 days.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf. If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

HOW TO FILE A GDPR COMPLAINT.

We hope that we can resolve any query or concern you raise about our use of your personal information.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

COMPLAINT COMPLIANCE

We maintain procedures for addressing and responding to all inquiries or complaints from you about our handling of personal information. We will inform individuals who make inquiries or lodge complaints of the existence of relevant complaint procedures. We may seek external advice where appropriate before providing a final response to individual complaints. We shall investigate all complaints. If a complaint is found to be justified, we will take appropriate measures, including, if necessary, amending our policies and procedures.

DO WE MAKE UPDATES TO THIS POLICY?

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may email us at hello@ocmpartners.com.