Privacy Guarantee

I. INTRODUCTION

When you use Onyx, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices.

This notice describes the personal data we collect, how it’s used and shared, and your choices regarding this data. We recommend that you read this along with our privacy overview, which highlights key points about our privacy practices.

Last modified: July 23, 2020 Effective date: July 20, 2020

II. OVERVIEW

Scope – This Notice Applies To Users Of Onyx’s Services Anywhere In The World, Including Users Of Onyx’s Apps, Websites, Features, Or Other Services.

This notice describes how Onyx and its affiliates collect and use personal data. This notice applies to all users of our apps, websites, features, or other services anywhere in the world. This notice specifically applies to: Clients: individuals who request or receive crew members, including those who are on another’s vessel Crew: individuals who provide, or submit applications to Onyx to provide, transportation individually or through partner transportation companies Delivery recipients: individuals who request or receive food, or other products and services Delivery partners: individuals who provide, or submit applications to Onyx to provide, delivery or other services All those subject to this notice are referred to as “users” in this notice.

III. DATA COLLECTIONS AND USES

A. The Data We Collect

Data provided by users to Onyx, such as during account creation
Data created during use of our services, such as location, app usage, and device data
Data from other sources, such as Onyx partners and third parties that use Onyx APIs
The following data is collected by or on behalf of Onyx:

1. Data provided by users. This includes:

User profile: We collect data when users create or update their Onyx accounts. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), government identification documents, including crew member’s license numbers and images, birthdate, signature, and photo. This also includes vehicle or insurance information of crew and delivery partners, and user settings. We may use the photos submitted by crew and/or delivery partners to verify their identities, such as through facial recognition technologies. For more information, please see the section titled “How we use personal data.”
Background check and identity verification: We collect background check and identity verification information for crew and delivery partners. This may include information such as crew member history or criminal record (where permitted by law), and right to work. This information may be collected by an authorized vendor on Onyx’s behalf. We also collect identity verification from Onyx Eats users who request alcohol delivery.
Demographic data: We may collect demographic data about users, including through user surveys. In some countries, we may also receive demographic data about users from third parties.
User content: We collect the information users submit when they contact Onyx customer support, provide ratings or compliments for other users or restaurant partners, or otherwise contact Onyx. This may include feedback, photographs or other recordings collected by users.

2. Data created during use of our services. This includes:

Location data: We collect precise or approximate location data from a user’s mobile device if enabled by the user to do so. For crew and delivery partners, Onyx collects this data when the Onyx app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device. For clients, delivery recipients, and renters, Onyx collects this data when the Onyx app is running in the foreground. In certain regions (which do not include the European Union), Onyx may also collect this data when the Onyx app is running in the background of the user’s mobile device. Clients, delivery recipients, and renters may use the Onyx apps without enabling Onyx to collect location data from their mobile devices. However, this may affect some functionality available in the Onyx apps. For example, a user who has not enabled location data collection will have to manually enter their address. In addition, the location data collected from a crew member or rental device during a trip will be linked to the client’s or renter’s account, even if they have not enabled location data to be collected from their device, including for purposes of receipt generation, customer support, fraud detection, insurance, and litigation.
Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided, order details, delivery information, date and time the service was provided, amount charged, distance traveled, and payment method. Additionally, if someone uses your promotion code, we may associate your name with that person.
Usage data: We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services used before interacting with our services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers. To learn more about these technologies, please see our Cookie Notice.
Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data.
Communications data: We enable users to communicate with each other and Onyx through Onyx’s mobile apps and websites. For example, we enable crew and clients, and restaurants or delivery partners and delivery recipients, to call, text, or send other files to each other (generally without disclosing their telephone numbers to each other). To provide this service, Onyx receives some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications. Onyx may also use this data for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our products and services, and for analytics.
Rental devices data: We collect data generated by rental devices, such as bicycles, scooters, or other light electric vehicles or devices, when they’re in use. This includes the date and time of use, and the location, route, and distance traveled. To the extent permitted by law, the location data collected from the rental device during the trip will be linked to the renter’s account, even if they have not enabled Onyx to collect location data from their mobile device.

3. Data from other sources. This includes:

User feedback, such as ratings, feedback, or compliments.
Users participating in our referral programs. For example, when a user refers another person, we receive the referred person’s personal data from that user.
Onyx account owners who request services for or on behalf of other users, or who enable such users to request or receive services through their accounts. This includes owners of Onyx for Business accounts.
Users or others providing information in connection with claims or disputes.
Onyx business partners through which users create or access their Onyx account, such as payment providers, social media services, or apps or websites that use Onyx’s APIs or whose APIs Onyx uses.
Vendors who help us verify users’ identity, background information, and eligibility to work, for regulatory, safety, and security purposes.
Insurance, vehicle, or financial services providers for crew and/or delivery partners.
Partner transportation companies (for crew or delivery partners who use our services through an account associated with such a company).
Publicly available sources.
Marketing service providers.
Onyx may combine the data collected from these sources with other data in its possession.

B. How We Use Personal Data

Onyx collects and uses data to enable reliable and convenient transportation, delivery, and other products and services. We also use the data we collect:

To enhance the safety and security of our users and services
For customer support
For research and development
To enable communications between users
To send marketing and non-marketing communications to users
In connection with legal proceedings
Onyx does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.

Onyx uses the data it collects for purposes including:

1. Providing services and features. Onyx uses the data we collect to provide, personalize, maintain, and improve our products and services. This includes using the data to:

Create and update users’ accounts.
Verify crew’ and delivery partners’ identity, background history, and eligibility to work.
Enable transportation, deliveries, and other services.
Offer, process, or facilitate payments for our services.
Offer, obtain, provide, or facilitate insurance, vehicle, invoicing, or financing solutions in connection with our services.
Track and share the progress of rides or deliveries.
Enable features that allow users to share information with other people, such as when clients submit a compliment about a crew member, when delivery recipients provide feedback for a restaurant or delivery partner, refer a friend to Onyx, split fares, or share ETA and location with their contacts.
Enable features to personalize users’ Onyx accounts, such as creating bookmarks for favorite places, and to enable quick access to previous destinations. We may, for example, present an Onyx Eats user with personalized restaurant or food recommendations based on their prior orders. Please see the section of this notice titled “Choice and transparency” to learn how to object to this use of personal data.
Enable Accessibility features that make it easier for users with disabilities to use our services, such as those that enable deaf or hard-of-hearing crew to alert their clients of their disabilities, allow only text messages from clients, and enable receipt of flashing trip request notifications instead of sound notifications on their mobile device.
Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.

2. Safety and security. We use personal data to help maintain the safety, security, and integrity of our services and users. This includes:

Screening clients, crew, and delivery partners before enabling their use of our services and at subsequent intervals, including through reviews of background checks, where permitted by law, to help prevent use of our services by unsafe crew and/or clients.
Using data from crew’ or delivery partners’ devices to help identify unsafe driving behavior such as speeding or harsh braking and acceleration, and to inform them of safer driving practices. We also use data from delivery partners’ devices to verify the type of vehicles they used to provide deliveries.
In certain regions, using information derived from crew member’s license photos, and other photos submitted to Onyx, for safety and security purposes. This includes Onyx’s Real-Time ID Check feature, which prompts crew and delivery partners to share a selfie before going online to help ensure that the crew member or delivery partner using the app matches the Onyx account we have on file. This also includes comparing photographs that we have on file against photographs (i) of other users to prevent identity-borrowing, and (ii) from public databases to verify user identity.
Using device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities.
Using user ratings and feedback to encourage compliance with our Community Guidelines and as grounds for deactivating crew and delivery partners with low ratings or who otherwise violated such guidelines in certain countries.

3. Customer support. Onyx uses the information we collect (including recordings of customer support calls with notice to and the consent of the user) to provide customer support, including to:

Direct questions to the appropriate customer support person
Investigate and address user concerns
Monitor and improve our customer support responses and processes

4. Research and development. We may use the data we collect for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us to improve and enhance the safety and security of our services, improve our ability to prevent the use of our services for illegal or improper purposes, develop new features and products, and facilitate insurance and finance solutions in connection with our services.

5. Enabling communications between users. For example, a crew member may message or call a client to confirm a pickup location, a client may contact a crew member to retrieve a lost item, or a restaurant or delivery partner may call a delivery recipient with information about their order.

6. Marketing. Onyx may use the data we collect to market our services to our users. This includes sending users communications about Onyx services, features, promotions, sweepstakes, studies, surveys, news, updates, and events.

We may also send communications to our users about products and services offered by Onyx partners. For example, if a user has placed an Onyx Eats order, we may provide recommendations, promotions, or ads about similar food offered by other Onyx partners. Although we may send users communications about Onyx partners’ products and services, we do not sell users’ personal data to, or share it with, such partners or others for purposes of their own direct marketing or advertising, except with users’ consent.

We may use the data we collect to personalize the marketing communications (including advertisements) that we send, including based on user location, past use of Onyx’s services, and user preferences and settings.

We may also send users communications regarding elections, ballots, referenda, and other political and notice processes that relate to our services. For example, Onyx has notified some users by email of ballot measures or pending legislation relating to the availability of Onyx’s services in those users’ areas.

7. Non-marketing communications. Onyx may use the data we collect to generate and provide users with receipts; inform them of changes to our terms, services, or policies; or send other communications that aren’t for the purpose of marketing the services or products of Onyx or its partners.

8. Legal proceedings and requirements. We may use the personal data we collect to investigate or address claims or disputes relating to use of Onyx’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

9. Automated decision-making

We use personal data to make automated decisions relating to use of our services. This includes:

Enabling dynamic pricing, in which the price of a ride, or the delivery fee for Onyx Eats orders, is determined based on constantly varying factors such as the estimated time and distance, the predicted route, estimated traffic, and the number of clients and crew using Onyx at a given moment.
Matching available crew and delivery partners to users requesting services. Users can be matched based on availability, proximity, and other factors. Please see here for further information about our matching process.
Determining crew member and delivery partner ratings, and deactivating crew, clients, and delivery partners with low ratings. For more information about how ratings are determined and used, please see here for client ratings, herefor crew member ratings, and here for delivery partner ratings. Please also see the section below titled “Ratings look-up” for further information.
Deactivating users who are identified as having engaged in fraud or activities that may otherwise harm Onyx, its users, and others. In some cases, such as when a user is determined to be abusing
Onyx’s referral program, such behavior may result in automatic deactivation.
Using crew member location information, and communications between clients and crew, to identify cancellation fees earned or induced through fraud. For example, if we determine by using such information that a crew member is delaying a client pickup in order to induce a cancellation, we will not charge the client a cancellation fee and will adjust the amounts paid to the crew member to omit such a fee. To object to such adjustment, please contact Onyx customer support.
To object to a deactivation resulting from these processes, please contact Onyx customer support.

C. Cookies And Third-Party Technologies

Onyx And Its Partners Use Cookies And Other Identification Technologies On Our Apps, Websites, Emails, And Online Ads For Purposes Described In This Notice.

Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. Onyx uses cookies and similar technologies for purposes such as:

Authenticating users
Remembering user preferences and settings
Determining the popularity of content
Delivering and measuring the effectiveness of advertising campaigns
Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services
We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.

Please see our Cookie Notice for more information regarding the use of cookies and other technologies described in this section.

D. Data Sharing And Disclosure

Some of Onyx’s products, services, and features require that we share data with other users or at a user’s request. We may also share data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes. Onyx may share the data we collect:

1. With other users

This includes sharing:

Clients’ first name, rating, and pickup and/or dropoff locations with crew.
Clients’ first name with other clients in a carpool trip. Clients in carpool trips may also see the dropoff location of the other clients.
Delivery recipients’ first name, delivery address, and order information with their delivery partner and restaurant. We may also share ratings and feedback, or other information to the extent required by law, with the restaurant partner and delivery partner.
For crew and delivery partners, we may share data with the client(s), delivery recipient(s), and restaurant partner(s), including name and photo; vehicle make, model, color, license plate, and vehicle photo; location (before and during trip); average rating provided by users; total number of trips; length of use of the Onyx app; contact information (depending upon applicable laws); and crew member or delivery partner profile, including compliments and other feedback submitted by past users. We also provide clients and delivery recipients with receipts containing information such as a breakdown of amounts charged, crew member or delivery partner first name, photo, route map, and such other information required on invoices in the country or region where the crew member or delivery partner operates.
For those who participate in Onyx’s referral program, we share certain personal data of referred users, such as trip count, with the user who referred them, to the extent relevant to determining the referral bonus.

2. At the user’s request

This includes sharing data with:

Other people at the user’s request. For example, we share a user’s ETA and location with a friend when requested by that user, or a user’s trip information when they split a fare with a friend.
Onyx business partners. For example, if a user requests a service through a partnership or promotional offering made by a third party, Onyx may share certain data with those third parties. This may include, for example, other services, platforms, apps or websites that integrate with our APIs; vehicle suppliers or services; those with an API or service with which we integrate; or restaurant partners or other Onyx business partners and their users in connection with promotions, contests, or specialized services.

3. With the general public

Questions or comments from users submitted through public forums such as Onyx blogs and Onyx social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user.

4. With the Onyx account owner

If a user requests transportation or places an order using an account owned by another party, we may share their order or trip information, including real-time location data, with the owner of that account.

5. With Onyx subsidiaries and affiliates

We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf.

6. With Onyx service providers and business partners

Onyx provides data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include:

Payment processors and facilitators
Background check and identity verification providers (crew and delivery partners only)
Cloud storage providers
Marketing partners and marketing platform providers, including social media advertising services
Data analytics providers
Research partners, including those performing surveys or research projects in partnership with Onyx or on Onyx’s behalf
Vendors that assist Onyx to enhance the safety and security of its apps
Consultants, lawyers, accountants, and other professional service providers
Fleet partners
Insurance and financing partners
Airports
Lime and other local providers
Restaurant partners and/or their point of sale providers
Vehicle solution vendors or third-party vehicle suppliers

7. For legal reasons or in the event of a dispute

Onyx may share users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns. This includes sharing personal data with law enforcement officials, public health officials, other government authorities, airports (if required by the airport authorities as a condition of operating on airport property), or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect Onyx’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. If you use another person’s credit card, we may be required by law to share your personal data, including trip or order information, with the owner of that credit card.

Please see Onyx’s Guidelines for Law Enforcement Authorities for more information.

This also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

8. With consent

Onyx may share a user’s personal data other than as described in this notice if we notify the user and they consent to the sharing.

E. Data Retention And Deletion

Onyx retains user profile, transaction, and other personal data for as long as a user maintains their Onyx account.

Onyx may retain certain user data after receiving an account deletion request if necessary, such as to comply with legal requirements.

Onyx retains user profile, transaction, and other information for as long as a user maintains their Onyx account. For crew and delivery partners, Onyx also retains vehicle and background check information (to the extent permitted by law) for as long as they maintain their Onyx account.

Clients and delivery recipients may request deletion of their account at any time through the Settings > Privacy menus in the Onyx app, or through Onyx’s Help Center. Following such requests, Onyx deletes the data that it is not required to retain for purposes of regulatory, tax, insurance, litigation, or other legal requirements. For example, Onyx retains location, device, and usage data for these purposes for a minimum of 7 years; while it retains such data, it may also use it for purposes of safety, security, fraud prevention and detection, and research and development. In certain circumstances, Onyx may be unable to delete a user’s account, such as if there’s an outstanding credit on the account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, Onyx will delete the account as described above.

Onyx may also retain certain information if necessary for purposes of safety, security, and fraud prevention. For example, if Onyx deactivates a user’s account because of unsafe behavior or security incidents, Onyx may retain certain information about that account to prevent that user from opening a new Onyx account in the future.

F. Grounds For Processing

We only collect and use personal data where we have lawful grounds to do so. These include processing user personal data to provide requested services and features, for purposes of Onyx’s legitimate interests or those of other parties, to fulfill our legal obligations, or based on consent.

We collect and use personal data only where we have one or more lawful grounds for doing so. Such grounds may vary depending on where our users are located, but generally include processing personal data:

a. To provide requested services and features

In order to provide our services, we must collect and use certain personal data. This includes:

User profile data, which we use to establish and maintain user accounts; verify user identity; communicate with users about their trips, orders, and accounts; and enable users to make payments or receive earning
Background trip information, which is used to verify an applicant’s eligibility to be a crew member or delivery partner
Driver and delivery partner location data, which we use to track trips and assist with navigation
Usage data, which is necessary to maintain, optimize, and enhance Onyx’s services, including to determine incentives, connect clients and crew, and calculate costs of trips and crew member earnings
Transaction information
Information relating to customer support

b. For purposes of the legitimate interests of Onyx or other parties

This includes using personal data to maintain and enhance our users’ safety and security. For example, we use personal data to prevent use of our services by users who have engaged in inappropriate or dangerous behavior, such as by retaining data of banned users to prevent their use of Onyx’s apps. We also use usage data to prevent matching of clients and crew for whom there is higher risk of conflict (for instance, because they have been the subject of prior complaints from other users).

This also includes purposes such as combating fraud; improving our services, direct marketing, research, and development; and enforcing Onyx’s Terms of Service.

In addition, it includes using personal data to the extent necessary for the interests of other people or the general public, such as in connection with legal or insurance claims, and to protect the rights and safety of others.

c. To fulfill Onyx’s legal obligations

For example, Onyx is subject to laws and regulations in many cities and countries that require it to collect and retain data about our users’ trips, and to provide copies of such data to the government or other authorities. We collect and use personal data to comply with such laws.

Onyx may also share data with law enforcement regarding criminal acts or threats to public safety, or requests by third parties pursuant to legal processes. For more information about such sharing, please see Onyx’s Guidelines for Law Enforcement Authorities – United States, Guidelines for Law Enforcement Authorities – Outside the US, and Guidelines for Third Party Data Requests and Service of Legal Documents.

d. With consent

Onyx may collect and use personal data based on the user’s consent. For example, we may collect personal data through voluntary surveys. Responses to such surveys are collected on the basis of consent and will be deleted once no longer necessary for the purposes collected.

A user who has provided consent to a collection or use of their personal data can revoke it at any time. However, the user will not be able to use any service or feature that requires collection or use of that personal data.

IV. Choice And Transparency

Onyx enables users to access and control the data that Onyx collects, including through:

In-app settings
Device permissions
In-app ratings pages
Marketing opt-outs
Onyx also enables users to request access to or copies of their data, changes or updates to their accounts, deletion of their accounts, or that Onyx restrict its processing of user personal data.

A. Privacy settings

Settings menus in the Onyx app for clients give them the ability to set or update their location-sharing preferences and their preferences for receiving mobile notifications from Onyx. Information about these settings, how to set or change these settings, and the effect of turning off these settings is described below.

Location data

Onyx uses clients’ device location services to make it easier to get a ride whenever they need one. Location data helps improve our services, including pickups, navigation, and customer support. Clients may enable or disallow Onyx to collect location data from their mobile devices through the Settings > Privacy menus in the Onyx app. Clients and delivery recipients can enable or disallow such collections through the settings on their mobile device.

Share Live Location (clients)

Clients who have enabled Onyx to collect location data from their mobile device may also enable Onyx to share their location with their crew member from the time the ride is requested to the start of the trip. This can help improve pickups for both crew and clients, particularly in crowded areas. Clients may enable or disable this feature through the Settings > Privacy menus in the Onyx app.

Emergency Data Sharing (clients)

Clients who have enabled Onyx to collect location data from their mobile device may also enable the Emergency Data Sharing feature that shares data with emergency police, fire, and ambulance services. Such data includes approximate location at the time the emergency call was placed; the car’s make, model, color, and license plate information; the client’s name and phone number; pickup and dropoff locations; and the crew member’s name. Clients may enable or disable this feature through the Settings > Privacy menus or the Safety Center in the Onyx app.

Notifications: account and trip updates

Onyx provides users with trip status notifications and updates related to activity on their account. These notifications are a necessary part of using the Onyx app and cannot be disabled. However, users may choose the method by which they receive these notifications through the Settings > Privacy menus in the Onyx app.

Notifications: discounts and news

Users may enable Onyx to send push notifications about discounts and news from Onyx. Push notifications may be enabled or disabled through the Settings > Privacy menus in the Onyx app.

Communications from restaurant partners

Delivery recipients who have opted in to communications from restaurant partners may stop sharing their data with each restaurant partner in their Onyx Eats account settings.

B. Device permissions

Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. iOS devices notify users the first time the Onyx app requests permission to access certain types of data and gives users the option to grant or refuse permission. Android devices notify users of the permissions that the Onyx app seeks before their first use of the app, and use of the app constitutes a grant of such permission.

C. Ratings look-up

After every trip, crew and clients are able to rate each other on a scale from 1 to 5. An average of those ratings is associated with a user’s account and is displayed to other users for whom they provide or receive services. For example, client ratings are available to crew from whom they request transportation, and crew member ratings are available to their clients.

This 2-way system holds everyone accountable for their behavior. Accountability helps create a respectful, safe environment for crew and clients. Clients can see their average rating in the main menu of the Onyx app. Crew can see their average rating after tapping their profile photo in the Onyx Driver app. Delivery partners are also rated by delivery recipients and restaurant partners. Click here for more information.

D. Marketing opt-outs

Users may opt out of receiving promotional emails from Onyx here. Users may also opt out of receiving emails and other messages from Onyx by following the unsubscribe instructions in those messages. We may still send users who have opted out non-promotional communications, such as receipts for rides or information about their account.

E. User data requests

Onyx provides users with a variety of ways to learn about, control, and submit questions and comments about Onyx’s handling of their data. To make a request, please go here.

Accessing data: Users can ask for an explanation of the data we collect from them and how we use it.

Receiving data: Users can ask for a copy of data that Onyx collects from them with their consent or as necessary to provide our services.

Changing or updating data: Users can edit the name, phone number, email address, payment method, and photo associated with their account through the Settings menu in Onyx’s apps or crew member portal. They may also ask that Onyx change or update their data, including if they believe such data is inaccurate or incomplete.

Deleting data: Users may request deletion of their account at any time through the Settings > Privacy menus in the Onyx app, or through Onyx’s website (clients and delivery recipients here; crew and delivery partners here).

Objections, restrictions, and complaints: Users may request that we stop using all or some of their personal data, or that we limit our use of their data. Onyx may continue to process data after such objection or request to the extent required or permitted by law.

In addition, depending on their location, users may have the right to file a complaint relating to Onyx’s handling of their personal data with the data protection authority in their country. For example, users in the European Union and South America may submit such requests to the data protection authorities in the country in which they live.

V. Updates To This Notice

We may occasionally update this notice. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.

We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Onyx apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices. After such notice, use of our services by users in countries outside the European Union will be understood as consent to the updates to the extent permitted by law.