Last updated on: 10 july 2026

OHM PLATFORM PRIVACY POLICY

At OHM (hereinafter – “OHM”, “we”, “us”, “our”, etc.), we respect your privacy and are committed to protecting your personal data.This Privacy Policy (hereinafter – the “Platform Privacy Policy” or “Policy”) outlines how we collect, store, use, share, and otherwise process personal data in connection with the OHM Platform and the Services made available through it.

This Platform Privacy Policy applies specifically to the OHM Platform available at https://www.emarka.com (hereinafter – “OHM Platform”), to the data processing conducted in relation to provision of the Services through the OHM Platform, and to your interactions with us in connection with such Services.

For any matters not expressly regulated by this Platform Privacy Policy, the OHM Agency Website Privacy Policy, as updated from time to time, shall apply to the extent appropriate and not inconsistent with this Platform Privacy Policy.

This Platform Privacy Policy should be read together with the OHM Terms of Service, Commercial Terms, and OHM Policies governing the use of the OHM Platform and the Services.

1. Definitions

For the purposes of this Policy:

“GDPR” means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

“CCPA (CPRA)” means the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, to the extent applicable.

“Personal Data or Personal Information” means any information relating to an identified or identifiable person or household who can be directly or indirectly identified or reasonably linked by reference to an identifier. This definition provides for a wide range of personal identifiers to constitute Personal Data, including an email address, identification number, device information, location data, or online identifiers, such as cookie files or similar technologies. This definition, when used in this Policy shall have the meanings attributed to the terms “Personal Data” and “Personal Information” by GDPR and CCPA (CPRA) accordingly.

“Processing” means any operation or set of operations performed on Personal Data or on sets of Personal Data, whether by automated or non-automated means, such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure, or destruction.

“You”, “Yours”, etc. refers to a data subject (under GDPR) or consumer (under CCPA (CPRA)) who is a visitor of the OHM Platform, signing up or registered, or Authorized User (if applicable) or prospective/existing clients communicating with us via special contact form on the OHM Platform, via email or by other means.

“Client” means the legal entity, business, undertaking, organisation, or commercial operator that applies for, accesses, uses, or receives the Services through the OHM Platform, as such term may be defined in the applicable OHM Terms of Service.

“Authorised User” means any employee, contractor, representative, officer, director, agent, consultant, or other individual authorised by the Client to access or use the OHM Platform or the Services, or to act on the Client’s behalf in connection with them.

“Data Controller” means the entity that determines the purposes and means of the Processing of Personal Data. For the purposes of this Platform Privacy Policy, the Data Controller is OHM INFLUMTR LTD – company registered under the laws of Cyprus under the number HE 432790 with a legal address at 19, Bouboulinas, 3032, Limassol, Cyprus, – which operates and manages the OHM Platform website and determines the purposes and means of the processing of Personal Data in connection with the OHM Platform.

OHM Contracting Entities providing Services to Clients under the OHM Platform Terms of Service or Commercial Terms, may process Personal Data as Data Processors of OHM INFLUMTR LTD or may receive Personal Data where this is necessary for service delivery, onboarding, support, billing, verification, compliance, payment handling, internal administration, or other operational reasons determined by OHM.

Where required by applicable law, or where the nature of a particular Processing activity so requires, a relevant OHM Group entity may act as a separate or joint controller in respect of that activity. In such case, additional information may be provided in the applicable Commercial Terms, onboarding communications, account communications, or supplementary privacy notice.

“Data Processor” means a person or entity processing Personal Data on behalf of a Data Controller for business purposes.

Unless the context requires otherwise, terms used in this Policy shall be interpreted consistently with the applicable OHM Terms of Service and applicable data protection law.

OHM, OHM Contracting Entity, Services, Commercial Terms, Processing Partner, Verification Provider, Advertising Platform, and other capitalised terms used but not defined in this Policy shall have the meanings given to them in the OHM Platform Terms of Service.

2. What data do we process and how do we do that?

In the course of providing the OHM Platform and the Services, we may automatically collect or you can voluntarily provide us with the the following information categories that may include your Personal Data which is further processed:

Account and сontact information. This may include name, business email address, phone number, job title, company name, and other account registration or contact details relating to the Client or its Authorised Users.
Business and verification information. This may include information relating to the Client’s business, ownership, management, registration, target markets, websites, licences, source of funds, source of business, and other information provided during onboarding, verification, reverification, or compliance review.
Identity information. Where required for onboarding, verification, or compliance purposes, this may include identification details like name, email, phone number, title whatsoever and related documents concerning directors, beneficial owners, representatives, or Authorised Users of the Client.
Payment and billing information. This may include billing contact details, payment-related information, transaction references, payment method information (incl. bank card information), invoicing information, and other data necessary for payment processing, billing, dispute handling, reconciliation, or fraud prevention.
Platform usage data. This may include information about the Client’s and Authorised Users’ interactions with the OHM Platform and the Services, including account activity, session data, logs, settings, support interactions, usage records, and technical events.
Technical data. This may include IP address, browser type, operating system, device information, online identifiers, login records, and other technical data collected through the OHM Platform or related systems.
Communications and support data. This may include correspondence with OHM, support requests, complaints, responses, investigation materials, and records of communications concerning the Services.
Client materials. This may include campaign-related, business-related, and operational materials uploaded, submitted, transmitted, or otherwise made available by or on behalf of the Client in connection with the Services, to the extent such materials contain Personal Data.

We collect Personal Data in the following situations:

when the Client or its Authorised Users provide information directly to us;
when the Client uses the OHM Platform or the Services;
when we receive information from Verification Providers, Processing Partners, Advertising Platforms, service providers, affiliates, or other third parties involved in the Services;
when we generate or infer information in the course of operating, securing, administering, and supporting the OHM Platform and the Services.

No children’s or special categories persona; data. We do not intentionally collect children’s data through the OHM Platform. The OHM Platform and the Services are intended for business use only.We do not intentionally request special category data unless this is strictly necessary, lawful, and appropriately protected under applicable law. If such data is provided to us without necessity, we may delete it or otherwise limit its processing.

3. Legal basis and purposes of Processing

We process Personal Data only where we have a valid legal basis for doing so. Depending on the context, we rely on the following legal grounds:

Consent, where consent is required or otherwise obtained.
Contractual necessity, where Processing is necessary for the provision of the OHM Platform or the Services, or for taking steps at the request of the Client before entering into a contract;
Legal obligation, where Processing is necessary to comply with applicable legal or regulatory obligations;
Legitimate interests, where Processing is necessary for our legitimate business interests and such interests are not overridden by the rights and interests of the relevant data subject;

The purposes of the Personal Data processing conducted under this Privacy Policy may include:

Provision of the OHM Platform and the Services. This includes account creation, authentication, platform access, service administration, account support, billing support, reporting, analytics, and operational communications.
Onboarding, verification, and compliance. This includes business verification, identity verification, reverification, KYB/KYC procedures, sanctions screening, fraud prevention, internal checks, and assessment of eligibility for the Services.
Payments, billing, and financial administration. This includes payment processing, invoicing, reconciliation, chargeback handling, dispute management, fraud review, and sharing necessary payment-related information with Processing Partners and other relevant service providers.
Security, monitoring, and platform integrity.This includes access control, authentication, logging, detection of abuse, technical troubleshooting, investigation of suspicious conduct, enforcement of the OHM Terms of Service, and protection of the OHM Platform and the Services.
Support, communications, and relationship management. This includes responding to requests, handling complaints, maintaining communications with Clients and Authorised Users, and providing notices relating to the OHM Platform or the Services.
Service improvement and internal analytics. This includes analysis of the use, performance, reliability, and functionality of the OHM Platform and the Services, provided that such Processing is carried out in accordance with applicable law.
Legal and regulatory compliance. This includes compliance with applicable law, lawful requests from authorities, dispute resolution, exercise or defence of legal claims, and protection of OHM’s rights and legitimate interests.

Where required by law, we will request consent before Processing Personal Data for a particular purpose.

As a matter of fact, we process your personal data mainly to provide, operate, and maintain the OHM Platform and to provide you the Services under the OHM Platform Terms of Service. The table below summarises the main categories of Personal Data processed through the OHM Platform, their sources, the legal grounds for processing, and the purposes of such processing:

Category of Personal Data

Source

Grounds for processing

Purposes of processing

Account and contact information

Client; Authorized user

Contractual necessity; legitimate interest

(1) Provision of the OHM Platform and the Services;
(2) Support, communications, and relationship management;
(3) Legal and regulatory compliance

Business and verification information

Client; Authorized user; third parties

Contractual necessity; legitimate interest

(1) Onboarding, verification, and compliance;
(2) Provision of the OHM Platform and the Services;
(3) Legal and regulatory compliance

Identity information

Client; Authorized user; third parties

Contractual necessity; legitimate interest

(1) Onboarding, verification, and compliance;
(2) Security, monitoring, and platform integrity;
(3) Legal and regulatory compliance

Payment and billing information

Client; Authorized user; third parties

Contractual necessity; legitimate interest

(1) Payments, billing, and financial administration;
(2) Provision of the OHM Platform and the Services;
(3) Legal and regulatory compliance

Platform usage and Technical data

User of the OHM Platform (incl. Authorized user); third parties

Contractual necessity; legitimate interest; consent (where required)

(1) Provision of the OHM Platform and the Services;
(2) Security, monitoring, and platform integrity;
(3) Service improvement and internal analytics

Communications and support data

Client; Authorized user; third parties

Contractual necessity; legitimate interest

(1) Support, communications, and relationship management;
(2) Provision of the OHM Platform and the Services;
(3) Legal and regulatory compliance

Client materials containing Personal Data

Client; Authorized user

Contractual necessity; legitimate interest

(1) Support, communications, and relationship management;
(2) Service improvement and internal analytics

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The table above sets out the main categories of Personal Data processed through the OHM Platform, their sources, the applicable legal grounds, and the principal purposes of processing. To the extent that any other categories of Personal Data or other processing activities or purposes arise in connection with the OHM Platform or the Services and are not expressly addressed in this section, such processing shall be subject to the OHM Website Privacy Policy, to the extent appropriate and not inconsistent with this Platform Privacy Policy.

Please note that this may include processing of your Personal Data for marketing communications, where applicable (see Section 3 of the OHM Website Privacy Policy). Kindly note that you can always unsubscribe from direct marketing communications at any time by using the opt-out form in one of the received emails or by contacting us here privacy@ohm.agency.

4. Data sharing and transfers

By default, we collect and process Personal Data for our own business purposes in connection with the OHM Platform and the Services. However, in the course of providing the Services, we may share Personal Data with the following categories of recipients:

Category of recipient

Description

OHM Group entities

We may share Personal Data within the OHM Group where this is reasonably necessary for the provision of the Services, account administration, compliance, support, billing, risk management, or internal business operations. This includes sharing to and between the OHM Contracting Entities.

Verification Providers

We may share Personal Data with Processing Partners for payment processing, billing, reconciliation, chargeback handling, fraud checks, compliance review, and related financial processes.

Processing Partners

We may share Personal Data with Processing Partners for payment processing, billing, reconciliation, chargeback handling, compliance review, fraud checks, and related financial processes.

Service providers / Advertising Platforms

We may share Personal Data with Advertising Platforms for creation and functioning of Client’s accounts therein, as well as with hosting providers, infrastructure providers, analytics providers, communications providers, technical support providers, and other service providers assisting us in the operation of the OHM Platform and the Services

Professional advisers and business counterparties

We may disclose Personal Data to legal advisers, auditors, insurers, consultants, and other professional advisers where reasonably necessary

Authorities and legal recipients

We may disclose Personal Data where required by applicable law, court order, regulatory request, or other lawful process, or where necessary to establish, exercise, or defend legal rights

As a global business, OHM may transfer Personal Data to countries outside the country in which the relevant data subject is located, including countries that may not provide the same level of data protection. Where required by law, we will apply appropriate safeguards to such transfers, including standard contractual clauses or other recognised transfer mechanisms.

We do not sell Personal Data to third parties. Where applicable law recognises “sharing” in a broader sense, we will honour valid opt-out rights in accordance with the OHM Website Privacy Policy and applicable law.

NOTE: when you provide your personal data directly to our Verification Providers or Processing Partners (e.g. within the KYB/KYC procedure or for the purposes of payment processing procedure completely hosted by a Processing Partner), your relevant personal data is mainly processed by such third parties acting as (sub)processors of the Data Controller but sometimes they may act as controllers of your data and in such cases the processing of your data shall be governed by the applicable privacy policies of such third parties.

5. Cookies, tracking technologies, and platform logs

‍A “cookie” is a small file containing information that is placed on your computer or other device when you visit and use a particular website, online service, feature, web-interface, or mobile application. Cookies allow the relevant cookie providers to gain information on how you interact with the relevant websites and which settings you used. This information also can help the providers to analyze ads performance and which offers may be the most relevant for you. The cookies themselves do not allow us to directly identify you without additional data, but they enable providers to create your online profile. The cookies may be either “first party cookies” (set by us) or “third party cookies” (set by third-party providers who work with us).

The OHM Platform may use cookies, tags, scripts, local storage, session technologies, and similar tools in order to operate, maintain, secure, and improve the OHM Platform and the Services.

These technologies may be used for:

authentication and session management;
security and fraud prevention;
remembering settings and preferences;
measuring performance and diagnosing technical issues;
internal analytics relating to the use of the OHM Platform.

To the extent the OHM Platform uses cookies or similar technologies, the general approach described in Section 5 of OHM Website Privacy Policy shall also apply, unless otherwise stated in this Platform Privacy Policy or in a platform-specific cookie notice.

In addition to cookies, we may maintain system logs and related records concerning account access, usage events, security events, and technical operations of the OHM Platform.

6. Data security and confidentiality

We implement appropriate technical and organisational measures designed to protect Personal Data against unauthorised access, loss, destruction, alteration, misuse, or disclosure. However, no system or method of transmission over the internet is fully secure, and we cannot guarantee absolute security.

We retain Personal Data for as long as reasonably necessary for the purposes described in this Policy, including for the provision of the Services, compliance with legal obligations, resolution of disputes, prevention of fraud, protection of OHM’s interests, and enforcement of contractual rights. Retention periods may vary depending on the type of data, the nature of the relevant Client relationship, applicable legal requirements, and operational necessity. Where Personal Data is no longer required, we may delete, anonymise, or otherwise securely dispose of it, subject to any legal or operational retention requirements.

Meanwhile, we give you the opportunity to control and influence the time we store and process your data, as specified in the “Your Rights” section of the Policy.

7. Your rights

Where GDPR or another applicable data protection law applies, relevant data subjects may have the following rights, subject to applicable limitations and conditions:

The right to be informed. In this Policy, we provide you with detailed information related to your personal data Processing.
The right to access information held about you. i.e., you may always get information about your data that we process.
The right to rectify your personal data if it is inaccurate, incomplete, or outdated.
The right to erasure (deletion or removal) of your personal data. The right to restrict (block) processing. When processing is restricted, we will continue to store your personal data, but not process it any further.
The right to data portability, which allows individuals to obtain and reuse their personal data for their own purposes across different services. This right allows users to easily move, copy, or transfer personal data from one IT environment to another in a safe and secure way, without hindrance to usability.
Rights related to automated decision-making, including profiling, as stated in Article 22 of GDPR. We are not making any decisions which might produce a legal effect on you based on automated processing without legal grounds.
The right to withdraw your consent (object) to direct marketing.
The right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint with your local supervisory authority if you have a concern about our processing practices.

In addition, users subject to CCPA (CPRA) have following rights in relation to the personal information that we hold about you:

Request to access information about the collection of personal information by us, as well as request the deletion of personal information.

Because the OHM Platform is a business-oriented platform, some rights requests may need to be coordinated through the relevant Client organisation where the relevant Personal Data is processed in the context of a Client account or business relationship.

To exercise applicable privacy rights, please contact us using the contact details communicated through the OHM Platform, the applicable Commercial Terms, or the general OHM privacy contact channels.

8. Relationship with the OHM Website Privacy Policy

This Platform Privacy Policy applies specifically to the OHM Platform and the Services provided through it. The OHM Website Privacy Policy continues to apply to OHM websites generally and shall also supplement this Platform Privacy Policy with respect to matters not expressly regulated here, including, where appropriate, general explanations of privacy rights, cookie practices, and general privacy contacts. In the event of any inconsistency between this Platform Privacy Policy and the OHM Website Privacy Policy, this Platform Privacy Policy shall prevail with respect to the OHM Platform and the Services.

9. Changes to this Platform Privacy Policy

We may amend or update this Platform Privacy Policy from time to time. Any such amendment may be published through the OHM Platform, communicated by email, through account communications, or by any other reasonable means. Unless otherwise stated, the updated Platform Privacy Policy shall become effective as of the date stated in the “Last updated on” field at the top of this Policy. Continued use of the OHM Platform or the Services after such effective date shall constitute acknowledgement of the updated Platform Privacy Policy.

10. Contact details

‍If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

OHM INFLUMTR LTD
Gregoriou Xenopoulou 30, Limassol 3106, Cyprus
Email: privacy@ohm.agency
Data protection officer contact: dpo@ohm.agency

As the personal data may be controlled by the said entity jointly with OHM Contracting Entity as determined in accordance with OHM Platform Terms of Service or its other partners and affiliated parties, it is important to note that the said legal entity is appointed as EU representative of such partners or affiliated parties in relation to matters concerning processing of personal data of the residents of the European Economic Area (EEA) or Switzerland, when such other joint controllers are located outside the EEA or Switzerland.

For avoidance of doubts, you can also submit your questions related to this Policy to the relevant OHM Contracting Entity by its contact details that shall be identified in the applicable Commercial Terms communicated to you, onboarding communication, account communication, or other written or electronic communication made available through the OHM Platform.