Legal & Privacy Policies

The Service is designed to provide a platform for You, as a Member of the Opportunity Network, to share and respond to global business opportunities. As a Member of the Opportunity Network, Your participation in the Service and Your contribution, use, and disclosure of materials through the Service is subject to this Agreement. No other use of the Service is intended or allowed.

As a Member of the Opportunity Network You will have the ability to submit global business Opportunities soliciting the participation of other Members of the Opportunity Network. As a Member of the Opportunity Network, Your Opportunities will be made available on the Service, and the other Members of the Opportunity Network may respond to You via the Service. You may also consider and, in your sole discretion, seek to participate in Opportunities posted by other Members.

The Network is comprised of two closed clubs (“Tiers”) : the ON Tier (“ ON”) and ON LITE (“ ON LITE ”) . The Members of each Tier will be able to interact with other Members of the same Tier. Also, Members of the ON Tier will be able to view and connect to Opportunities from the ON LITE Tier, but not vice versa. In addition, Trusted Partners may establish Private Clubs for certain Members where Members can only interact with other Members of the same Private Club.

As a Member of the Opportunity Network, You may not respond to Opportunities submitted by another Member of the Opportunity Network in any manner or for any purpose other than that which is permitted by these Terms of the Service and the Agreement.

Communications via the platform that constitute advertising or marketing are prohibited. As a Member of the Opportunity Network, You may not send (or encourage or help others to send) unsolicited commercial email to our Members of the Opportunity Network.

As a User and a Member of the Opportunity Network You may only post or connect to business opportunities on behalf of the Member and about business concerning the Member company only.

As a Member of the Opportunity Network, You may not delete or revise any material contributed by any other person or entity.

Any conduct by a Member of the Opportunity Network that in our sole discretion restricts or inhibits any other Member of the Opportunity Network from using or enjoying the Service is prohibited.

As a Member of the Opportunity Network, You are strictly prohibited from the use of the Service for any purpose that violates any law applicable to You or the business You conduct through the Service including, without limitation, competition and anti-trust laws, employment and anti-discrimination laws, anti-corruption laws, anti-money laundering and trafficking laws, and securities regulation laws, such as laws prohibiting insider trading.

Furthermore, as a Member of the Opportunity Network, You understand and agree that opportunities concerning, but not limited to, firearms and weapons, counterfeit currency, stamps, currencies, credit cards, illegal drugs, nuclear energy, offensive material (ethnically, sexually or racially offensive material), embargoed goods and prohibited countries (please consult the information provided below, which shall be guidance but not exhaustive, and You are encouraged to consult with experts from Your geography), are prohibited and shall not be posted on the platform, and will not, in any case, be approved for live posting by Opportunity Network.

https://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R0855

https://sanctionsmap.eu/#/main

Subject to the User’s and/or Member of the Opportunity Network’s compliance with these Terms of the Service and the Agreement, Opportunity Network hereby grants the permission to use the Service, provided that: (aa) the User’s and/or Member of the Opportunity Network’s use of the Service as permitted is solely for business to business use, and the User and/or the Member of the Opportunity Network are not permitted to resell or charge others for use of or access to the Service, or use the Service in any other manner inconsistent with these Terms of the Service and the Agreement; (bb) the User and/or the Member of the Opportunity Network will not duplicate, transfer, give access to, copy or distribute any part of the Service in any way without Opportunity Network’s prior written authorization; (cc) the User will use the Service solely for and on behalf of the Member, never for other companies; and (dd) the User and/or the Member of the Opportunity Network will not attempt to reverse engineer, alter, scrape or modify any part of the Service.

Any materials You, as a Member of the Opportunity Network, submit concerning Opportunities may not contain (aa) URLs or links to websites that compete with Opportunity Network; (bb) copyrighted material (unless You own the copyright or have the owner’s permission to submit the copyrighted material or otherwise have the right to submit them); (cc) trade secrets (unless You own them or have the owner’s permission to submit them or otherwise have the right to submit them); (dd) material that infringes on or misappropriates any other intellectual property rights, or violates the privacy or publicity rights of others; (ee) anything sexually explicit, obscene, libelous, defamatory, threatening, harassing, abusive, or hateful; (ff) anything that is embarrassing or offensive to another person or entity; or (gg) Your direct contact information.

As a Member of Opportunity Network, You acknowledge that You shall not post any opportunity related to:

(a) Counterfeit currency and stamps

(b) Credit cards

(c) Publicly traded securities, publicly-traded financial or investment products

(d) Firearms, weapons, and ammunition. The category “Firearms, weapons, and ammunition” shall not include those that have the exclusive purpose of collecting, exhibition, hunting, and sport shooting

(e) Buying or selling currency (fiat and crypto)

(f) Controlled drugs and drug paraphernalia

(g) Controlled chemicals

(h) Prohibited/sanctioned countries

(i) Prohibited/sanctioned organizations and individuals

(j) Goods, materials, and substances which are subject to sanctions, embargoes, or other prohibition

(k) Offensive material – e.g. include ethnically, sexually or racially offensive material

(l) Weapons of mass destruction, and missiles capable of delivering such weapons

(m) Nuclear, chemical or biological weapons

(n) Radioactive or hazardous substances

(o) Endangered animal or plant species.

As a Member of the Opportunity Network, You may not use Your submission of Opportunities to (aa) impersonate another person, living or dead; (bb) disseminate false, inaccurate or misleading information; (cc) promote chain letters or pyramid schemes; or (dd) violate any law or regulation, or encourage others to violate any law or regulation.

Materials from any third party charging a fee are not permitted.

We are under no obligation to monitor the materials submitted by a Member of the Opportunity Network, but we may do so at our sole discretion. At any time, we may take any action concerning the materials submitted by a Member of the Opportunity Network that we deem in our sole discretion to be necessary or appropriate.

Users and/or Members of the Opportunity Network are prohibited from violating or attempting to violate the security of the Service, including without limitation: (aa) accessing data not intended for such Member of the Opportunity Network or logging into a server or account that the Member of the Opportunity Network is not authorized to access; (bb) attempting to probe, scan or test the vulnerability of a system or network or to breach security or authentication measures without proper authorization; (cc) attempting to interfere

with service to any user, host or network including, without limitation, through submitting materials like malicious software code, overloading, “flooding”, “mailbombing” or “crashing”; (dd) sending unsolicited e-mail, including promotions and/or advertising and/or marketing of products or services; or (ee) forging any TCP/IP packet header or any part of the header information by any e-mail or submission (collectively, the “Security Rules”).

Violation of these Security Rules may result in civil or criminal liability. We will investigate occurrences that may involve such violations and may involve, and cooperate with, law enforcement authorities in prosecuting Users and/or Members of the Opportunity Network who are involved in such violations.

The use of the Service is a privilege. As a Member of the Opportunity Network, You agree that You are solely responsible for Your conduct and use of the Service, and that of Your Users, and any consequences resulting from Your or their use of the Service.

We act as a service provider for Members of the Opportunity Network to publicize Opportunities. We do not undertake responsibility for screening or monitoring Opportunities. If You, as a Member of the Opportunity Network, respond to any Opportunity or enter into any transaction, agreement, contract, arrangement, partnership, collaboration, investment or other dealing arising out of or in any way related to any Opportunity with another Member of the Opportunity Network based on an Opportunity (“Transaction”), You agree that You are solely responsible for the consequences of such Transaction. We make no recommendation that You, as a Member of the Opportunity Network, should participate in Opportunities, either generally or about any particular Opportunity, and we make no representation that Your participation in any Opportunity will be beneficial to You. As a Member of the Opportunity Network, You agree to perform Your due diligence on each Opportunity, the other parties involved, and other relevant considerations such as identifying the source of funds, before entering into any Transaction based on the Opportunity.

Although we endeavor to extend membership in the Service only to legitimate individuals and companies, we do not perform any background verification on Members of the Opportunity Network. We assume no responsibility for the actions, conduct, or omissions of our Members of the Opportunity Network. As a Member of the Opportunity Network, You agree to perform Your due diligence on any Member of the Opportunity Network with whom You decide to do business, before entering into any transaction.

We are under no obligation to monitor the conduct of our Member of the Opportunity Network, but we may investigate and respond when violations are reported. As a Member of the Opportunity Network, You may report inappropriate materials contributed by others or conduct to abuse@opportunitynetwork.com We are not required to make any such investigation, and we will not be liable to any User and/or Member of the Opportunity Network for taking or not taking any action.

Opportunity Network reserves the right to temporarily or definitely suspend a Member if the Member was breaching these Terms of the Service or the Agreement.

Except as expressly stated in this Agreement, and except for the submission of Opportunities shared by the Members of the Opportunity Network, we reserve all our rights to all materials on the Service including, without limitation, written content, graphical and design elements (including the Service’s “look and feel”), and service marks and trademarks. As a Member of the Opportunity Network, You may not sell, transfer or assign any products or services or Your rights to any products or services provided by Opportunity Network to any third party without our express written authorization. As a Member of the Opportunity Network, You may not copy, modify, scrape, alter, or excerpt (or encourage or help others to copy, modify, alter, or excerpt) the Service materials. As a Member of the Opportunity Network, You may not use (or encourage or help others to use) the Service for any purpose or in any manner that is prohibited by the Agreement or by applicable law or regulation. As a Member of the Opportunity Network, You acknowledge and agree that this Agreement does not convey in any way any right, title or interest to You, or alter Your right, title or interest in any materials on the Service including, without limitation, any statutory or common law copyright, patent or other intellectual property right in such materials.

The Opportunities contributed by the Members of the Opportunity Network remain the property of those who contribute them. As a Member of the Opportunity Network, You must not share the Opportunities with any other individual or entity. As a Member of the Opportunity Network, You must not use, and must not allow anyone else to use, the Opportunities for any purpose at all, except to respond to the Opportunities through the Service.

We use commercially reasonable efforts to keep the Service available twenty-four hours a day, seven days a week, subject to scheduled downtime for maintenance purposes. We attempt to schedule downtime at times that minimize the impact to the Members of the Opportunity Network. Due to causes outside of our control, including conditions on the Internet and the services of our and Your Internet service providers, we can make no guarantees that any Member of the Opportunity Network will be able to access the Service at all times. We implement industry-standard measures to protect against service failures, but we shall not be liable to You for the inaccessibility to the Service due to causes outside of our control.

We make no representations or warranties whatsoever regarding the Service and any materials on the Service. NOTWITHSTANDING ANYTHING TO THE CONTRARY IN THESE TERMS OF SERVICE OR ELSEWHERE, THE SERVICE IS PROVIDED ON AN “AS IS” BASIS. TO THE FULLEST EXTENT PERMITTED BY LAW, WE HEREBY DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED INCLUDING, WITHOUT LIMITATION, ANY IMPLIED WARRANTY OF FITNESS FOR A PARTICULAR PURPOSE, ANY IMPLIED WARRANTY OF NON-INFRINGEMENT AND ANY IMPLIED WARRANTY OF MERCHANTABILITY. WE MAKE NO WARRANTY ABOUT THE ACCURACY, RELIABILITY, COMPLETENESS OR TIMELINESS OF THE SERVICE. WE MAKE NO

WARRANTY THAT THE SERVICE WILL BE UNINTERRUPTED, THE SERVICE’S FUNCTIONS SHALL BE ERROR-FREE OR, THAT THE SITE OR THE SERVERS THAT MAKE IT AVAILABLE ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS.

You are a Member of the Opportunity Network and Your use of the Service, the Internet, any materials You submit or access via our Service, and Your conduct online or offline are at Your own risk.

As a Member of Opportunity Network, You undertake to (and to procure that Your Users at all times) shall comply with all applicable laws and regulations that apply to You and that You shall have all requisite authorizations, licenses, and other permissions as necessary to carry out activities on the platform and to otherwise use the Services. Further, You shall not (and shall procure that Your Users shall not) use the platform or otherwise use the Services in connection with the offering of publicly traded securities, publicly-traded financial or investment products, financial services or any other activity which would require authorizations, licenses and other permissions as necessary to carry out activities on the Platform or which would require either the User, the Member, the platform or Opportunity Network to be licensed or regulated.

You acknowledge that Opportunity Network is not authorized by the Financial Conduct Authority to carry on a licensed or regulated activity, and it, therefore, does not carry on any licensed or regulated business.

We are not liable for any behavior of a Member of the Opportunity Network (or its Users) while using the Service or in the course of subsequent relationships between Members of the Opportunity Network (if any), including in cases of fraud, misconduct, negligence, and any illegal behavior by a Member of the Opportunity Network (or its Users).

Each Member shall act on its account in respect of any Opportunity and You acknowledge and agree that Opportunity Network will not act as agent, or principal, in respect of any Transaction.

Each Member is responsible for assessing the suitability of each Transaction which it enters into and agrees and acknowledges that each Transaction will be conducted outside of the platform and without the assistance of Opportunity Network.

Nothing in this Agreement or placed on the Service by Opportunity Network shall be deemed legal, accounting, or securities advice.

Under no circumstances will we be liable for any loss or damage caused by Your reliance on information obtained through the Service. As a Member of the Opportunity Network, You are responsible to evaluate the accuracy, completeness, or usefulness of any information, opinion, advice, or other content available through the Service. Please seek the advice of professionals, as appropriate, regarding the evaluation of any specific information, opinion, advice, or other content.

Further, we explicitly disclaim any responsibility for the accuracy, content, or availability of information found on a site that links to or from the Service (a “third-party site”). We may offer links to, or incorporate into the Service, third-party sites that offer various products and/or services. We cannot ensure that the Members of the Opportunity Network will be satisfied with any products or services that are purchased from such a third-party site since such sites are owned and operated by independent retailers. We do not endorse any of such products or services, nor have we taken any steps to confirm the accuracy or reliability of any of the information contained in any third-party sites. We do not make any representations or warranties as to the security of any information (including credit card and other personal information) users might be requested to give a third-party site. We strongly encourage Members of the Opportunity Network to make their own investigation of third-party sites before proceeding with any transaction with such third parties.

We do not endorse, and nothing on the Service shall be deemed to be an endorsement, representation, or warranty of, any third party, whether concerning such third party’s products, services, websites, experience, or background or otherwise. We do not make any representations or warranties concerning any materials submitted by Members of the Opportunity Network, including Opportunities posted by them.

We respect the intellectual property of others, and we ask You, as a Member of the Opportunity Network, to do the same. If You are a copyright owner or an owner’s agent and find content on our website that infringes upon Your copyrights, You may submit a notification to us. To do so, please send an email to on@opportunitynetwork.com and provide us in writing the following information:

1. i) A physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed;
2. ii) Identification of the copyrighted work claimed to have been infringed, or if multiple copyrighted works at a single online site are covered by a single notification, a representative list of such works at that site;

iii) Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit us to locate the material;

1. iv) Information reasonably sufficient to permit us to contact You, as a Member of the Opportunity Network, such as an address, telephone number, and, if available, an electronic mail;
2. v) A statement that the complaining party has a good-faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law; and
3. vi) A statement that the information in the notification is accurate, and under penalty of perjury, that the complaining party is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

As a Member of the Opportunity Network, You shall indemnify and defend Opportunity Network, and our officers, employees and consultants against any costs, expenses (including reasonable attorneys’ fees whether arising out of a third-party claim or in enforcing this indemnification), claims, judgments, settlements and damages (including all damages awarded to third parties payable by Opportunity Network, but in all cases only our direct damages) arising out of, or related to, Your use of the Service, including any Opportunities submitted by any Member of the Opportunity Network to the Service or provided to other Members of the Opportunity Network by You, and/or also including, but not limited to, any claim that Your submission of the Opportunities infringes the intellectual property rights of any person, violate securities or other laws, including laws against “insider trading,” or any violation of the Agreement.

Neither we, nor any of our officers, directors, employees or agents, will be liable to You, AS A USER AND/OR MEMBER OF THE OPPORTUNITY NETWORK, or to any other person for any indirect, consequential, punitive or special damages (“non-direct damages”), of any character, whether in an action in contract, tort or otherwise, arising out of or in connection with these Terms, even if we have been advised of the possibility of such damages.

The liability of OPPORTUNITY NETWORK and any of our officers, directors, employees or agents to You, AS A USER AND/OR MEMBER OF THE OPPORTUNITY NETWORK, or to any other person for direct damages shall be limited to the greater of EURO100 or the fees paid by You for our services during the 12 months preceding the events that give rise to Your first claim against us for damages.

NO OTHER PERSON OR ENTITY SHALL HAVE ANY LIABILITY TO YOU, AS A USER AND/OR MEMBER OF THE OPPORTUNITY NETWORK, FOR ANY CLAIM ARISING OUT OF THIS AGREEMENT OR THE SERVICES PROVIDED BY OPPORTUNITY NETWORK. AS A USER AND/OR MEMBER OF THE OPPORTUNITY NETWORK, YOU HEREBY WAIVE ANY SUCH CLAIM YOU MAY HAVE AGAINST ALL THIRD-PARTIES, INCLUDING, WITHOUT LIMITATION ANY TRUSTED PARTNER, OR ANY MEMBERSHIP ASSOCIATION OR ORGANIZATION OR OTHER ENTITY OR PERSON THAT SPONSORS OR PAYS FOR YOUR MEMBERSHIP IN THE SERVICE.

Because some states or jurisdictions do not allow the exclusion or limitation of liability for non-direct damages, the limitations in THE FIRST paragraph above may not apply to You, AS A USER AND/OR MEMBER OF THE OPPORTUNITY NETWORK, but in such CASE, the limitations in THE SECOND paragraph shall apply to both direct and non-direct damages.

You, as a Member of the Opportunity Network, and we agree to resolve any claims relating to the Agreement or the Service provided by Opportunity Network through final and binding arbitration, except either You or we may bring a lawsuit solely for injunctive relief to stop unauthorized use or abuse of the Service or to protect intellectual property (for example, trademark, trade secret, copyright, or patent rights) from infringement without first engaging in arbitration.

The International Chamber of Commerce will administer the arbitration under its Commercial Arbitration Rules and the Supplementary Procedures for Consumer-Related Disputes. The arbitration will be held in London, or any other location You and we agree to. The ICC rules will govern payment of all arbitration fees.

Exceptions to Agreement to Arbitrate: You, as a User and/or a Member of the Opportunity Network, may only resolve disputes with Opportunity Network on an individual basis, and may not bring a claim as a plaintiff or a class member in a class, consolidated, or representative action. Class arbitrations, class actions, private attorney general actions, and consolidation with other arbitrations aren’t allowed.

In the case of a lawsuit for injunctive relief as described above or in event that the agreement to arbitrate is found not to apply to You, as a User and/or Member of the Opportunity Network, or Your claim, You and we irrevocably consent and agree that legal action, suit or proceeding against either You or Us may be brought only in the United Kingdom, and only the Courts of London shall be competent, and You hereby irrevocably accept and submit to the exclusive jurisdiction of the aforesaid courts in personam, for any such action, suit or proceeding.

The Agreement and any claim or dispute (including non-contractual disputes) arising out of, relating to or in connection with the Agreement, whether in contract, tort or otherwise, shall be governed by and construed in accordance with the laws of England and Wales without giving effect to its conflicts of law principles.

As a Member of the Opportunity Network, You shall send notices to Opportunity Network by mail or by email to on@opportunitynetwork.com . Notices to You will be sent by mail or by email to the addresses You provide when registering. Notices shall be deemed given on the day received by the recipient if received as provided in this paragraph before 5 pm on a business day in the recipient’s location. Notices received after 5 pm or on a non-business day shall be deemed received on the next business day.

The Agreement may change from time to time, and if we make material changes to it, we will provide notice through our platform, or by other means, to provide You the opportunity to review the changes before they become effective. If You object to any changes, You may contact on@opportunitynetwork.com to opt-out of specific new features or to close Your Membership and bring the Agreement to an end.

You acknowledge that Your continued use of our Service after we publish or send a notice about our changes to the Agreement and/or the Privacy Policy means that the collection, use, and sharing of Your personal data (including on a cross-border basis) is subject to the updated Privacy Policy. We may change the Agreement and/or the Privacy Policy at any time.

In any jurisdiction where any of the Agreement cannot be enforced, including any rights in intellectual property, the Agreement shall be construed in such jurisdiction in all respects as if such unenforceable provision were omitted. Also, in such jurisdiction, there shall be added automatically as a part of this Agreement an enforceable provision that is as similar to such unenforceable provision as may be possible.

Nothing in this Agreement is intended to, or shall be deemed to, establish any partnership or joint venture between Us and You (or any User), constitute us or You (or any User) the agent of the other, or authorize us or You (or any User) to make or enter into any commitments for or on behalf of the other.

In respect of Opportunities posted by others in which You, as a Member of the Opportunity Network, participate which constitute, or will result in, securities transactions, or similar, under applicable law or regulation, You represent and warrant, by Your participation, that You have the status of “sophisticated investor” (or variants such as “professional investor”; “institutional investor”; “accredited investor”) or other necessary status or qualification to so participate.

In respect of Opportunities in which You, as a Member of the Opportunity Network, participate (i.e. when posted by others) or post (i.e. by a User on Your behalf) which constitute, or will result in, securities transactions, or similar, under applicable law or regulation, You represent and warrant that You do so for Your own account (on an infrequent and “principal” basis), and not as agent or nominee on behalf of any person or entity, and that, in doing so, You will not be engaging in a business of dealing in securities, or operating a brokerage, and that You will comply with applicable securities laws and regulations including, without limit, in respect of any applicable prospectus requirements.

You further agree that Opportunity Network does not, in the course of providing the Service, participate in or make an offer of securities about any Opportunity which You post to the platform and to indemnify and hold harmless Opportunity Network in respect of any such finding or any breach of paragraphs (a) and (b) above.

Opportunity Network and You, as a Member of the Opportunity Network, are solely independent parties of each other. Neither party shall be deemed in default for failure to comply with any provision hereof, if such failure results from acts or events beyond its reasonable control, other than payment of money. If any provision of this Agreement is found to be invalid, illegal or unenforceable, the validity, legality and enforceability of the remaining provisions shall not in any way be affected or impaired thereby. We are not obligated to enforce the Agreement, but no failure to enforce the Agreement, even if repeated and continuing for a prolonged period, shall constitute a waiver of any part of the Agreement, which may be done only by a written agreement properly signed on our behalf. All provisions of this Agreement, except provisions that grant You access to or use of the Service, shall survive the termination of the agreement between Opportunity Network and You. These This Agreement shall be binding upon the parties, their legal representatives, successors and permitted assigns, but may not be assigned by You. Except as may be expressly stated in any other written agreement between You and us, the Agreement, including any part thereof, (as amended from time to time by us as provided in the Agreement) contain the entire understanding between You and us and supersede any prior agreement between You and us, whether written oral.

Depending on the company of our group You contact, Your data may be processed as a controller by one or more of the following companies(“US”). You will be informed at due course which Opportunity Network entity/ies control and process your Personal Data.

• Opportunity Network International UK Ltd., a private limited company incorporated on April 24, 2015, under the laws of the United Kingdom, with registered office address at 20 Old Bailey, London, United Kingdom, EC4M 7EG, filled with the Companies House under number 09559477.
• Opportunity Network Spain S.L., a private limited company incorporated under the Spanish laws, with registered office address at Av. Diagonal 512, Bajos Interior, 08036 Barcelona, Spain, with Spanish tax ID number (“NIF”) B66427709, and registered in the Commercial Register of Barcelona in Volume 44612, Sheet 160, Page B-461178.
• Opportunity Network Holdings Ltd., a private limited company incorporated under the laws of the United Kingdom, with registered office address at Third Floor, 20 Old Bailey, London EC4M 7AN, filled with the Companies House under number 9516905.
• Opportunity Network North America LLC, a private limited company incorporated the US laws, with registered office address at 210 Rivington Street, apt 9, New York, NY 10002, United States, with EIN 47-4557595.

Opportunity Network Inc. a private limited company incorporated under U.S. laws, with a registered office address at 210 Rivington Street, apt 9, New York, NY 10002, United States, with EIN 61-1735817.

We collect information to provide, maintain, protect, and improve the Service we offer to our Members of the Opportunity Network and to develop new services. We also use the information to protect Opportunity Network and the information of the Members and related Users. Unless expressly stated otherwise at the time of collection, all Personal Data collected are mandatory for the purposes described in this Policy. Thus, failure to provide them may prevent Us from processing the User’s request or otherwise fulfilling the purposes described below. By providing Opportunity Network with Your data, You warrant that the data provided is accurate, true, and up-to-date in all respects.

In respect of each of the purposes for which we use Your Personal Data, applicable law may require us to ensure that we have a legalbasis for that use. The legal bases depend on the Services You use and how You use them. This means we collect and use Your PersonalData or Company information only where:

• We need it to provide You with the Services, including to operate the Services, provide customer support and personalizedfeatures and to protect the safety and security of the Services;
• Processing of Your Personal Data and company information is necessary for the performance of a contract to which You are aparty;
• It satisfies a legitimate interest (which is not overridden by Your data protection interests), such as for research and development,to market and promote the Services and to protect our legal rights and interests; or
• We need to process Your data to comply with a legal or regulatory obligation.

We may also rely on Your consent as a legal basis for using Your Personal Data where we have expressly sought it for a specific purpose.We have set out below, more detailed examples of relevant purposes for which we may use Your Personal Data.

1) To enable Your registration, verify Your identity on the Platform and verify the Member You represent fulfils Our eligibility requirements.

Type of data:

(a) Identity (e.g. passport id, power of attorney).

(b) Contact (e.g. name, email address, phone number, country where the company is registered, company name).

Lawful basis for processing:

(a) Performance of a contract (T&Cs) to which You are a party or in order to take steps at Your request prior to entering into a contract (T&Cs).

(b) Necessary for our legitimate interests (to prevent fraudulent activities).

2) To authenticate You via LinkedIn, Google, Facebook or Apple ID. In such cases we will use Your user’s name on Your LinkedIn, Google, Facebook, or Apple ID account so that it will be visible to other Members and Users of the Platform and website.

Type of data:

(a) Contact (e.g. full name, profile picture, position, company description and information)

(b) Log-in details.

Lawful basis for processing:

(a) Your consent.

3) To enable Us to include Your personal information in past and current opportunities posted on the Platform.

Type of data:

(a) Contact (e.g. full name, profile picture and position.

(b) We may include other non-personal information such as company name, company description and company information.

Lawful basis for processing:

(a) Our legitimate interest to increase connections in the platform while increasing transparency on the Platform.

4) To show other members relevant information regarding Your activity and Your profile on the platform.

Type of data:

(a) Contact (e.g. full name, profile picture, company name, company description and information)

(b) Activity on the platform (e.g. amount of connections, amount of posts, timing of the responses)

Lawful basis for processing:

(a) Legitimate interest to ensure that our members would access important information about each other.

(b) Performance of a contract (T&Cs) with You.

5) To enable notifications on the Platform for You

Type of data:

(a) Contact (e.g. email address)

(b) Activity on the Platform regarding Your connections, new search results on Your search list, replies, Your saved opportunities, Your activity on the platform and other important messages.

Lawful basis for processing:

(a) Performance of a contract (T&Cs) to which You are party

(b) Legitimate interest to facilitate sales on the Platform

6) To enable You to communicate with other members.

Type of data:

(a) Contact (e.g. Your profile)

(b) Name of the member You are communicating with.

(c) Messages including date and time of messages, shared photos and attachments.

(d) Information whether another member has seen Your message.

(e) Information whether You had a videocall with another Member and the duration of such call. We don’t have access to the content of such calls.

(f) Other data submitted in messages.

Lawful basis for processing:

(a) Performance of a contract (T&Cs) with You.

(b) Legal basis for storing the removed message data is the compliance of our legal obligation to ensure the safety of our Platform by detecting and preventing fraudulent activity or misuse of the platform, which is in the interest of both the company and its users.

7) To address Your public feedback about us (e.g. feedback on the App Store or Google Play)

Type of data:

(a) Contact.

(b) Information You choose to include as feedback.

(c) Date and time of feedback.

(d) Technical data related to Your browser.

(e) Device type and operating system.

Lawful basis for processing:

(a) Legitimate interest to manage Opportunity Network’s reputation.

8) To send You important communication regarding the Platform (e.g. providing important notifications such as T&Cs, Payment Policy and Privacy Policy changes).

Type of data:

(a) Contact (e.g. email address)

Lawful basis for processing:

(b) Performance of a contract (T&Cs) with You

(c) Compliance with the legal obligations to which Opportunity Network is subject.

9) To send You and other Users/Members of the Platform relevant opportunities posted in the Platform via Our Oppmailer and Platform feed, including in such communications Your personal information already provided to us.

Type of data:

(a) Contact information about the members who posted such opportunities (e.g. full name, position, profile picture, company, industry)

(b) Activity on the Platform

Lawful basis for processing:

(a) Our legitimate interest to provide opportunities to our Members and increase connections in the Platform

10) To provide our customer service and support. As part of our Premier Services, we will help You post, connect, and interact with other Members of the platform.

Type of data:

(a) Contact (e.g. profile).

(b) Activity on the platform.

(c) Face recording.

(d) Voice recording.

(e) All other information You choose to provide while communicating with Your Account Executive or Account Manager.

Lawful basis for processing:

(a) Performance of a contract (compliance with our T&Cs) to which You are a party.

(b) Our legitimate interest to track Our communications with you in case any issue arises.

(c) Consent whenever You choose to include any other personal information.

11) To resolve any disputes related to payments or renewals on the platform.

Type of data:

(a) Contact (e.g. full name, company name and company description)

(b) Activity on the platform

(c) Billing information

(d) Messages and any other forms of communication with other Members or with Your Account Executive or Account Manager

Lawful basis for processing:

(a) Our legitimate interest to settle disputes between our members and defend the rights and interests of Opportunity Network

(b) Compliance with the legal obligations to which Opportunity Network is subject.

(c) Performance of a contract (T&Cs) with You.

12) To improve Your preferences regarding Your feed and search results by enabling You to personalize Your feed and search results, providing You relevant suggestions keeping Your previous searches, sending You notifications and otherwise making the use of Platform more pleasant.

Type of data:

(a) Contact (e.g. full name, position, company industry, business type, business interest, company’s country and targeted region).

(b) Activity on the platform (e.g. search history and date and time of Your search).

Lawful basis for processing:

(a) Your consent.

(b) Our legitimate interest to improve results on the Platform.

13) To personalize Your feed and search results.

Type of data:

(a) Contact (e.g. Your position, company type, language)

(b) Activity on the Platform (e.g. Your browsing activity on the platform, company’s industry, company’s type, posted opportunities, type of business and all other information provided by You or provided by You to Your Account representative).

Lawful basis for processing:

(a) Our legitimate interest of Opportunity Network and its members to make the Platform more convenient for our members and, due to personalization, allow You to see offers from other members that might interest You the most.

14) To manage activity by Main Accounts in relation to Team/Child account, at all times.

Type of data:

(a) Team/Child Account’s Contact (e.g. their profile)

(b) Team/Child Account’s activity on the Platform (e.g. posted opportunities, connections, messages)

Lawful basis for processing:

(a) Performance of a contract (T&Cs) with You.

(b) Our legitimate interest to enable Main Account Members to manage all information related to their activity.

15) To prioritize good value opportunities by reputable members.

Type of data:

(a) Contact (e.g. company type, language, company’s country, company’s industry, company’s type, posted opportunities)

(b) Activity on the Platform (e.g. number of connections and savings

Lawful basis for processing

(a) Performance of a contract (T&Cs) with You.

(b) Our legitimate interest to prioritize good value items by reputable sellers in order to facilitate sales and member satisfaction on the Platform.

16) To suggest You relevant opportunities descriptions.

Type of data:

(a) Contact

(b) Public available information (e.g. company descriptions).

Lawful basis for processing:

(a) Performance of a contract (T&Cs) with You.

(b) Our legitimate interest to improve the Platform and ensure that our members receive relevant suggestions of potential opportunities.

17) To improve our Platform.

Type of data:

(a) Contact

(b) Activity on the Platform (e.g. button clicks, visiting time, notifications read, other information depending on a particular business case)

Lawful basis for processing:

(a) Our legitimate interest to maintain performance and improve the Platform

18) To better understand how Members interact with our website.

Type of data:

(a) Contact

(b) Activity on the Platform

(c) Information included as feedback (e.g. Your satisfaction with the platform, Your needs for the platform, problems that You encounter using the platform)

Lawful basis for processing:

(a) If You wish to participate in the survey, the information above will be collected based on Your consent

19) To track visits to the Platform.

Type of data:

(a) Contact

(b) Logfiles (e.g. User ID; IP address of Your device; Browser used by Your device; Content and URLs You connect to; Date and time of Your connections; Model and manufacturer of Your mobile device and Operating system used by Your mobile device (iOS, Android, etc).

Lawful basis for processing:

(a) Our legitimate interest to protect the Platform and ensure its security and the legitimate interest of our members to ensure the safety of their accounts on the Platform

20) To let You reset Your password.

Type of data:

(a) Security questions and answers

(b) Contact

(c) Registration date

(d) Last transaction information

Lawful basis for processing:

(a) Our legitimate interest to protect the Platform and ensure its security and the legitimate interest of our members to ensure the safety of their accounts on the Platform

(b) Performance of a contract (T&Cs) with You

21) To verify Your account in case of suspicious actions related to Your account.

Type of data:

(a) Contact (e.g. email address)

Lawful basis for processing:

(a) Our legitimate interest to protect the Platform and ensure its security and the legitimate interest of our members to ensure the safety of their accounts on the Platform

(b) Performance of a contract (T&Cs) with You.

22) To carry out payment source security check.

Type of data:

(a) Contact

(b) Billing information (e.g. photo of the payment card or information contained in a photo/screenshot of the bank statement listing the most recent charge/charges: date and description of the last Opportunity Network charge, other payment information if the member chooses not to blur out other information)

Lawful basis for processing:

(a) Our legitimate interest to protect the Platform and ensure its security and the legitimate interest of our members to ensure the safety of their accounts on the Platform

(b) Performance of a contract (T&Cs) with You

23) To verify that items sold through our platform are authentic. Though we make every effort to authenticate items such as artworks, jewelry or precious stones that are being sold through our platform, we cannot guarantee the authenticity of all items and are not responsible for any counterfeit products.

Type of data:

(a) Contact

(b) Legal authentication document

Lawful basis for processing:

(a) Legitimate interest to protect the Platform and our members from eventual counterfeit.

(b) Performance of a contract (T&Cs) with You.

(c) Compliance with the legal obligations to which Opportunity Network is subject.

24) To facilitate the exercise of intellectual property rights.

Type of data:

(a) Contact

(b) Right’s owner, IP rights, copyrights, patents, trademark, design data

Lawful basis for processing:

(a) Our legitimate interest to protect the Platform and our members from intellectual property infringements.

(b) Performance of a contract (T&Cs) with You.

(c) Compliance with the legal obligations to which Opportunity Network is subject.

25) To enable You to block a Member for spam, abusive, harmful conduct or other behavior.

Type of data:

(a) Reported content, reporting reason, information provided in the report and date and time of Your report.

(b) Contact information

(c) Activity on the Platform

(d) Identity

Lawful basis for processing:

(a) Our legitimate interest to protect the Platform and ensure its security and the legitimate interest of our members to ensure the safety of their accounts on the Platform

(b) Performance of a contract (T&Cs) with You.

(c) Compliance with the legal obligations to which Opportunity Network is subject.

26) To ensure the security of the Platform and its members.

Type of data:

(a) Contact

(b) Identity

(c) Activity on the platform

Lawful basis for processing:

(a) Our legitimate interest to protect the Platform and its users and ensure its security and the legitimate interest of our members to ensure their safety on the Platform.

(b) Performance of a contract (T&Cs) with You.

(c) Compliance with the legal obligations to which Opportunity Network is subject.

27) To moderate Your activity on the platform.

Type of data:

(a) Contact

(b) Activity on the platform

(c) Messages

(d) Identity

Lawful basis for processing:

(a) Our legitimate interest to protect the Platform and its users and ensure its security and the legitimate interest of our members to ensure their safety on the Platform.

(b) Performance of a contract (T&Cs) with You

(c) Compliance with the legal obligations to which Opportunity Network is subject

28) To suspend a Member on the platform.

Type of data:

(a) Contact

(b) Activity on the platform

(c) Messages

(d) Identity

Lawful basis for processing:

(a) Our legitimate interest to protect the Platform and its users and ensure its security and the legitimate interest of our members to ensure their safety on the Platform.

(b) Performance of a contract (T&Cs) with You.

(c) Compliance with the legal obligations to which Opportunity Network is subject.

29) To pay for a subscription and issue refunds.

Type of data:

(a) Contact (e.g. full name, fiscal number, company)

(b) Billing information (e.g. credit card information, banking information and billing address)

Lawful basis for processing:

(a) Performance of a contract (T&Cs) with You.

30) To determine the effectiveness of promotional campaigns and advertising, and for periodic review by electronic means (email, phone calls or messages, postal service, etc.) of the usability of the Platform as well as sending information on our Services.

Type of data:

(a) Contact

(b) Activity on the campaign

Lawful basis for processing:

(a) Our legitimate interest to present You with marketing messages that we consider relevant to You

(b) Performance of a contract (T&Cs) with You

31)To enable us to post Your content on our social media account.

Type of data:

(a) Contact

(b) Information You choose to include in Your posts or comments.

Lawful basis for processing:

(a) Consent

32) To allow You to see personalized advertisements.

Type of data:

(a) IP address and/or mobile device identifier; Advertising ID; Information on websites browsed by the visitor; list of pages and products viewed, clicked, put in a basket or bought the Platform; URL of the pages viewed by the visitor (“referrer”), URL of the previous page viewed by the visitor; Technical information related to the browser, device type and operating system version of the visitor (“user-agent”); Timestamp (date, time); Information about the possible relationships among different browsers and devices.

Lawful basis for processing:

(a) Our legitimate interest to increase the effectiveness of advertising campaigns, leading to higher revenue for the company.

(b) Our legitimate interest to improve user experience by sending personalized ads that allows us to provide more relevant and useful content to users, enhancing their overall experience on the platform

33) To provide commercial communications that we think will be of interest to You and similar to those contracted by You by Opportunity Network.

Type of data:

(a) Contact (e.g. email address, company industry)

(b) Activity on the platform (e.g. type of connections)

Lawful basis for processing:

(a) Our legitimate interest to present You with marketing messages that we consider relevant to You

34) To handle Your requests related to personal data.

Type of data:

(a) Contact

(b) All data contained in Your request in addition to any other data held by Opportunity Network

Lawful basis for processing:

(a) Compliance with the legal obligations to which Opportunity Network is subject.

35) To provide information to law enforcement and other state institutions.

Type of data:

(a) Contact

(b) Activity on the platform

(c) All data held by Opportunity Network to the extent necessary to comply with law enforcement requests.

Lawful basis for processing:

(a) Compliance with the legal obligations to which Opportunity Network is subject.

36) To defend our rights and interest of Opportunity Network.

Type of data:

(a) Contact

(b) Billing information

(c) All data held by Opportunity Network to the extent necessary to resolve a particular situation.

Lawful basis for processing:

(a) Our legitimate interest to defend our rights in case a chargeback procedure is initiated against Opportunity Network

We collect information in four ways:

3.1 Information You give to us.

3.1.1 You provide data to create an account with us. To create an account You need to provide data including but not limited toYour full name, email address, mobile number, password, . For example, when the User in country where the company isregistered, company name and position in the company. If You register for a Premium Service, You will need to providepayment (e.g., credit card) and billing information.

3.1.2 You provide data to create a profile on the platform. You have a choice about the information on Your profile, such as Yourprofile picture, company’s industry, headquarters location, company’s size, company revenue, company’s website and all other information You include as a company description. Please do not post or add personal data or confidential information to Your profile that You would not want to be publicly available.

3.1.3 You provide data when You post or provide it to our Service. We collect personal data from You when You provide, post orupload it to our Services, such as when You fill out a form or respond to a survey.

3.2 Information from others.

3.2.1 We may receive Your personal data (e.g. Your job title, profile picture and work email address) about You in the event You were referred from a Trusted Partner or when You choose to log in with Your LinkedIn, Apple ID or Facebook account.

3.2.2 We may receive personal data from Third Party providers (e.g. ID verification providers) to provide our Services.

3.3 Information we get from the use of our Services about the User, the Member and the Service that the User in name and on behalf of a Member of the Opportunity Network uses.

3.3.1We receive log usage data when You visit or otherwise use our Services, including our sites, app and platform technology,such as when You view or click on content or ads (on or off our sites and apps), perform a search, install or update one ofour mobile apps, post opportunities, connect with other Members in the platform and all other activities You do in ourPlatform. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify You and log Your use.

3.3.2 We collect information about You when You send, receive, or engage with messages in connection with our Services. Forexample, if You get a connection request, we track whether You have acted on it and will send You reminders.

3.4 Information publicly available

3.4.1 We collect information publicly available (e.g. from Your company’s website) about Your company to include in Your profileand on current opportunities (e.g. Member’s company description). Starting from May 2023, prior to written communicationto You, we will include in all current Opportunities -including those already published in the Platform- relevant informationabout Your company that is publicly available in Your company’s website and Your personal information (e.g. full name,profile picture, position) that You have already provided to Us in Your profile and, unless You choose to object timely. Such information will be included in all current Opportunities already published on the platform, except for sell-side M&A Opportunities.

The information we collect from the Users and/or the Members of the Opportunity Network includes:

• Contact Information of the Users that allows Us to communicate with them, such as name but not limited to name,last name, email address, phone numbers, position, date of birth, citizenship, education, company tax residence, company name,corporate information, company’s address, fiscal number, company description, social media links, websites and profile picture.
• Identity Information to verify Your identity as a User and authorizations to represent the Member such as identity card, powerof attorney, etc.
• Administrative Information of the Members and Potential Members like, for instance, billing information and and credit cardinformation.
• Relationship Information that helps Us to understand who the Potential Members, the Members, and Users are and what types of Services the Members might like. This includes geographical and industrial focus information. Also, we will collect feedback Users and Members voluntarily share with Us. Also, to provide our customer support Services we record the meetings held between You and Your Account Manager/Executive, collecting Your voice and face recording as well as all other information You choose to include in such meetings.
• Transaction Information about how Users and Members interact with Opportunity Network, such as connections requested, Opportunities shared, and whether Users and Members open an email we send them.
• Cookies may be used to analyze the Services usage, improve the content, customize our website content and layout, and for other customer service purposes. Cookies are text files that are stored in a computer system via an Internet browser. Through the use of cookies, Opportunity Network can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.
• User’s IP Addresses are automatically logged when a User visits the Opportunity Network’s webpage. The IP Address is used to help identify the User and to gather demographic information about our Users on the website. Our servers may also record: the pages the User visits on our website; the advertising the User sees and/or clicks on; computer, platform, related software, and settings the User is using when accessing the platform; any search terms the User has entered on our website or a referral site; any other web usage activity and data logged by Opportunity Network’s servers. We use this information for internal system administration, as well as to help diagnose problems with the servers and to administer our website. Such information may also be used to gather demographic information, such as country of origin and Internet Service Provider.
• Log information we automatically collect and store in server logs when the User in name and on behalf of the related Member uses our Services or views content provided by Opportunity Network. This may include information and details related to Users and Members, such as:

– details of how our Service is used, such as search queries and information and accessed pages;

– device-specific information (such as hardware model, operating system version, unique device identifiers);

– Internet protocol address; and/or

– cookies that may uniquely identify used browser or Opportunity Network account.

We do not share information with companies, organizations and individuals outside of Opportunity Network without the consent of theUsers and the related Members.

Nonetheless, please note that information regarding the User and the represented Member may be communicated to thefollowing categories of recipients:

a) For Legal Reasons. We will share information with companies, organizations, or individuals outside of Opportunity Network if we have a good-faith belief that access, use, preservation or disclosure of them is reasonably necessary to:

• meet any applicable law, regulation, legal process or enforceable governmental request;
• enforce applicable Terms and Conditions, including investigation of potential violations;
• detect, prevent, or otherwise address fraud, security or technical issues; and/or
• protect against harm to the rights, property, or safety of Opportunity Network, our Users and Members, or the public as required or permitted by law.

b) With other Users and Members. Information provided to us may be shared with other Users and Members of the Platform inorder to improve connections among Members and Users of the Platform. Besides Opportunities that are posted on the platform,we may share Your Opportunities through our Oppmailer to other Members who we think would be interested in connecting withYou, including in such communications Your personal information (e.g. full name, position, company and company description). Inaddition, main account Users will have access to all their team/child Accounts personal and non-personal information collected byOpportunity Network, including but not limited to messages, connections, and opportunities. Before posting an opportunity please verify the type of information you are sharing with members among the platform and search engines. In the event you choose to post an opportunity anonymously please opt-out from sharing Your information by switching off the opt-in options before posting.

c) With Trusted Partners. When the Member’s memberships have been created via invitation received from a Trusted Partner, the Trusted Partner receives information concerning its Members, such as when Members join Opportunity Network, share opportunities, and create connections. The Trusted Partner may process the information of its invited Members of the Opportunity Network to single out and report opportunities such Members may be interested in or offer services that may help such Members achieve an Opportunity.

d) With Search EnginesMany of our Services let the Member of Opportunity Network share information with others. Remember that when You share Yourpersonal information publicly (e.g. post an Opportunity on the Platform), it may be indexable by search engines. Our Servicesprovide the Member with different options for sharing and removing content. Please carefully review the information included inYour Opportunity before publishing it.

e) With Service Providers.These parties help us provide the Services or perform business functions on our behalf. They include:

• Hosting, technology and communication providers.
• Security and fraud prevention consultants.
• Support and customer service vendors.
• Product fulfilment and data analytic companies.
• Payment processing vendors.

f) With Benefits Providers. When You sign up for Benefits, we will share certain data with the relevant Benefits Provider to establish and enable the provision of the Benefit.

g) Anonymized Data. We may also share aggregated, non-personally identifiable information publicly, and with our partners. Forexample, we may share information publicly to show trends about the general use of our Services.

h) To Fulfil And Comply With Contractual Relationships. Please be informed that Opportunity Network, when necessary to fulfiland comply with contractual relations, may communicate Personal Data to:

• Entities with which payment management is performed, such as bank agencies or entities, solely for this purpose.
• Auditors, lawyers, accounting firms and other external consultants and suppliers of products or services to the company.

We work hard to protect Opportunity Network and our Users and/or Members of the Opportunity Network from unauthorized access to orunauthorized alteration, disclosure or destruction of information we hold. We review our information collection, storage and processingpractices, including physical security measures, to guard against unauthorized access to systems.We restrict access to Personal Information to Opportunity Network employees, contractors and agents who need to know that informationin order to process it for Us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated ifthey fail to meet these obligations.In addition, we inform You that Opportunity Network can count on or collaborate with companies outside the European Union. In thosecases, Opportunity Network requires that these companies comply with the measures designed to protect personal data established in abinding contract, except in cases where the European Commission has determined that, the country where said companies are locatedprovide for an adequate level of protection of personal data.We will not make Your Personal Data available to third parties for any other purposes as described in this Privacy Policy.Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may includeOpportunity Network Services or other sites linked from our Services. Our Privacy Policy does not cover the information practices of othercompanies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offerrelevant ads.

Your Rights.

You have the right to:

• Request access to Your personal data (commonly known as a ” data subject access request”). This enables You to receive acopy of the personal data we hold about You and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about You. This enables You to have any incomplete or inaccuratedata we hold about You corrected, though we may need to verify the accuracy of the new data You provide to us.
• Request erasure of Your personal data. This enables You to ask us to delete or remove personal data where there is no goodreason for us continuing to process it. You also have the right to ask us to delete or remove Your personal data where You havesuccessfully exercised Your right to object to processing (see below), where we may have processed Your information unlawfullyor where we are required to erase Your personal data to comply with local law. Note, however, that we may not always be able to comply with Your request of erasure for specific legal reasons which will be notified to You, if applicable, at the time of Your request.
• Object to processing of Your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about Your particular situation which makes You want to object to processing on this ground as You feel it impacts on Your fundamental rights and freedoms. You also have the right to object where we are processing Your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process Your information which override Your rights and freedoms.
• Request restriction of processing of Your personal data. This enables You to ask us to suspend the processing of Your personal data in the following scenarios: (a) if You want us to establish the data's accuracy; (b) where our use of the data is unlawful but You do not want us to erase it; (c) where You need us to hold the data even if we no longer require it as You need it to establish, exercise or defend legal claims; or (d) You have objected to our use of Your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of Your personal data to You or to a third party. We will provide to You, or a third party You have chosen, Your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which You initially provided consent for us to use or where we used the information to perform a contract with You.
• Withdraw consent at any time where we are relying on consent to process Your personal data. However, this will not affect the lawfulness of any processing carried out before You withdraw Your consent. If You withdraw Your consent, we may not be able to provide certain products or services to You. We will advise You if this is the case at the time You withdraw Your consent.

Contact Us. To that effect the User may send an email to legal@opportunitynetwork.com, enclosing a copy of its ID or equivalent official document certifying its identity. We may reject unreasonably repetitive requests, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), or risk the privacy of others.

Data Protection Authorities. Furthermore, if appropriate, the User also has the right to make a complaint to the relevant data protection supervisory authority, e.g. the Spanish Data Protection Authority (“AEPD”) or the UK Data Protection Authority (“ICO”), especially if he/she considers that Opportunity Network has not adequately addressed its rights.

We will retain Your personal information for as long as it is necessary for the purposes listed in this Privacy Policy and in no case longer than legally permitted. We maintain a data retention policy that we apply to all data in our care. As long as the personal data is no longer necessary for the fulfillment of the contract or its initiation or if the law does not require us to keep it, it will be securely deleted from our servers.

On our website, Users are allowed to subscribe to Opportunity Network newsletters. We inform the Member of Opportunity Network and business partners through newsletters about Opportunity Network offers and updates. Opportunity Network newsletters may only be received if (a) the Member has a valid e-mail address, and (b) the Member registers for newsletters shipping. Opportunity Network newsletters contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, Opportunity Network may see if and when an e-mail was opened by a Member, and which links in the e-mail were called up by Members.

The Services are not intended for or designed to attract any person under the age of 18 or of the different legal age provided by each country in which the User has access to our Services. Opportunity Network does not intentionally or knowingly collect or maintain Personal Information or non-personally identifiable information from any person under the age of 18 or of the different legal age provided by each country in which the User has access to the Services. If Opportunity Network learns that Personal Information of persons under the age of 18 or of the different legal age provided by each country in which the User has access to the Services has been collected on the Service’s platform, then Opportunity Network may deactivate the User’s account.

Storage. Opportunity Network is committed to ensuring that the User’s information is kept and stored securely, and we maintain reasonable physical, technical and organizational measures, and procedures to safeguard and secure the information we collect through our Services and our website. This has been done to prevent unauthorized or unlawful processing of the User’s Personal Information and accidental, unauthorized or unlawful access, use, processing, copying, alteration, transfer, loss or destruction of, or damage to Personal Information. We review our information collection, storage, and processing practices, including physical security measures, to guard against unauthorized access to systems.

Access by Employees. We restrict access to Personal Information to Opportunity Network employees, contractors, and agents who need to know that information to process it for Us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may include Opportunity Network Services or other sites linked from our Services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags, and other technologies to serve and offer relevant ads.

Potential Security Breaches. Whilst Opportunity Network has done all of this to comply with the standards required by applicable laws, Opportunity Network cannot guarantee that such information will not be subject to unauthorized access, disclosure, alteration or destruction, Opportunity Network has physical, electronic, and procedural safeguards in place to protect information. Information is stored on Opportunity Network’s servers and protected by secured networks to which access is limited to a few Opportunity Network’s authorized employees and personnel. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. If Opportunity Network learns of a security systems breach, then we may attempt to notify the User electronically so that he/she will be able to take appropriate protective steps. We may also have the obligation to contact the relevant Data Protection Authority according to the current legislation in force. Furthermore, Opportunity Network may also post a notice on the Service platform whether a security breach occurs.

If Opportunity Network is involved in a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, Opportunity Network reserves the right to transfer or assign Users’ and Members’ information to the new entity. As part of such a transaction, the new entity shall be required to commit to the same level of protection of the User’s and Members’ information as described in this Privacy Policy. If Opportunity Network will not be able to obtain such a commitment, we will not perform the business transition. Opportunity Network shall post a notice on the Service of every change in ownership or control of the Users’ and Members’ information that may occur. The User acknowledges and accepts that in the event of Opportunity Network’s bankruptcy, insolvency, reorganization, receivership, and/or assignment for the benefit of creditors, and/or the application of laws or equitable principles affecting creditors’ rights generally, Opportunity Network may not be able to control how the User’s and Members’ information will be treated, transferred, or used.

The Opportunity Network website and Service are mostly hosted in the United Kingdom and partially in Belgium. If You are a User accessing the Opportunity Network website and Service from the United States, the European Union, Asia, or any other region with laws or regulations governing Personal Information collection, use, and disclosure, that differ from the United Kingdom and/or European Union laws, please be advised that through Your continued use of the Opportunity Network website and Service, which are governed by United Kingdom law, and the Agreement, including this Privacy Policy, You are transferring Your Information to the United Kingdom and You expressly consent to that transfer and consent to be governed by United Kingdom law for these purposes.

Our Privacy Policy may change from time to time, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide You the opportunity to review the changes before they become effective. If You object to any changes, You may contact on@opportunitynetwork.com to opt-out of specific new features or to close Your Membership. You acknowledge that Your continued use of our Service after we publish or send a notice about our changes to this Privacy Policy means that the collection, use, and sharing of Your personal data is subject to the updated Privacy Policy.

Depending on the company of our group You contact, Your data may be processed as a controller by one or more of the following companies. You will be informed at the due course which Opportunity Network entity/ies control and process your Personal Data.

• Opportunity Network International UK Ltd., a private limited company incorporated on April 24, 2015, under the laws of the United Kingdom, with registered office address at 20 Old Bailey, London, United Kingdom, EC4M 7EG, filled with the Companies House under number 09559477.
• Opportunity Network Spain S.L., a private limited company incorporated under the Spanish laws, with registered office address at Carrer de Bretón de los Herreros, 9, 08012 Barcelona, Spain, with Spanish tax ID number (“NIF”) B66427709, and registered in the Commercial Register of Barcelona in Volume 44612, Sheet 160, Page B-461178.
• Opportunity Network Holdings Ltd., a private limited company incorporated under the laws of the United Kingdom, with registered office address at Third Floor, 20 Old Bailey, London EC4M 7AN, filled with the Companies House under number 9516905.
• Opportunity Network North America LLC, a private limited company incorporated the US laws, with registered office address at 210 Rivington Street, apt 9, New York, NY 10002, United States, with EIN 47-4557595.
• Opportunity Network Inc. a private limited company incorporated under U.S. laws, with registered office address at 210 Rivington Street, apt 9, New York, NY 10002, United States, with EIN 61-1735817.

Cookies (jointly, “ Cookies ”) are small data files that are generated on Your computer and that store the information generated by Your activity on the Website. Our Website opportunitynetwork.com (“ Website ”) may use different types of Cookies as listed and explained in more detail in the following paragraph 3 (“What Cookies do We use on our Website?”).

Generally speaking, cookies proprietary of one webpage may be sent to a user’s terminal equipment from a computer or domain managed by such a webpage and from which the requested service is provided. On the other hand, there may be third-party cookies sent to a user’s terminal equipment from a computer or domain that is not managed by the said webpage, but by another entity that processes the data obtained through cookies. A website may also use session cookies (i.e. cookies collecting and storing data while a user accesses a website). Lastly, there are the so-called persistent cookies. Persistent cookies are stored in a user’s terminal so that the collected data can be accessed and processed during a period defined by the entity responsible for the cookie, which could range all the way from a few minutes to several years. For the avoidance of doubt, users do not provide this information directly. Rather than that, these data are automatically collected as a means of supporting a user’s visit to a website.

At the Opportunity Network Website, we use the following Cookies corresponding to the following purposes:

1. Technical cookies (i.e. own csfr token session Cookies). These Cookies enable the User to browse through the Website using the different features and services, for example, session cookies which allow to identify the User session or to carry out the authentication for access to restricted areas.
2. Statistical Cookies (i.e. third-party Google Analytics and Mouseflow Cookies). These Cookies enable Opportunity Network to quantify the number of Users and to implement the measurement and statistical analysis of the Services usage. Therefore, Opportunity Network analyzes the User’s browsing on the Website in order to improve the offered Services.

Additional information about Mouseflow and Google Analytics is available here:

https://support.google.com/analytics/answer/6004245

https://mouseflow.com/privacy/

You are hereby informed that under the Privacy and Data Protection regulations in force, we do have the right to store Cookies on Your device if these Cookies are strictly necessary for the operation of this Website.

Whenever your preferences and/or statistics Cookies make You personally identifiable, Opportunity Network will process Your Personal Data based on our legitimate interest in providing You with the best service on the website and to evaluate, improve and simplifying the performance of our Website.

Any potential Advertising Cookies may and will only be used if and after We have obtained Your express consent to do so. For the avoidance of the doubt, Advertising Cookies are used to track Website Users to display relevant and attractive ads for the User and are, therefore, more valuable for publishers and third-party advertisers. As a consequence, Your express acceptance of Advertising Cookies may involve the communication, whenever the Cookies are identifiable, of the information on the use You make of the Website with our partners of social networks, advertising and web analysis, who may combine them with other information that You have given them or that they have collected from the use You have made of their services.

We inform You that You can revoke at any time the consent given for the use of Cookies, by configuring Your browser in the terms provided in this section. However, You must bear in mind that preventing the use or installation of any specific type of Cookies may affect or hinder the access to and/or provision of certain Services offered on the Website.

Depending on the browser used, the installation options can be found in different sections. Please, consult the instructions of Your browser if You want to know how to block or allow the installation of Cookies.

For the following browsers, You can find more information in the following links:

• Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
• Chrome: http://support.google.com/chrome/bin/answer.py?hl=es&answer=95647
• Internet Explorer: http://windows.microsoft.com/es-es/windows7/how-to-manage-cookies-in-internet-explorer-9

Safari: http://support.apple.com/kb/ph5042

Opportunity Network may modify this Cookies Policy according to statutory requirements or regulations, as well as to adapt this Cookies Policy to the instructions issued by the relevant data protection authorities. Therefore, Users are advised to visit this page periodically to revise whether any changes have been made.

To find out more about cookies, please visit www.allaboutcookies.org or www.youronlinechoices.eu.

If You have any questions, comments, or suggestions on our Cookies Policy, please contact Opportunity Network at on@opportunitynetwork.com.