Privacy Policy (archived)

This is not the most up-to-date version of our privacy policy. Find the current privacy policy here.

Effective as of 12/16/2024

Please click here to view the previous version of our Privacy Policy.

This Privacy Policy describes how Frnge, Inc. (d/b/a Fringe) ("Fringe," "we", “us” or "our") processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, social media pages, marketing activities, live events and other activities described in this Privacy Policy (collectively, the “Service”)). 

Fringe provides a lifestyle benefits and wellbeing marketplace to facilitate employee stipends, rewards, and recognition programs. This Privacy Policy does not apply to information that we process on behalf of our business customers (such as businesses and other organizations) while providing the Fringe platform to them. Our use of information that we process on behalf of our business customers may be governed by our agreements with such customers. If you have concerns regarding your personal information that we process on behalf of a business customer, please direct your concerns to that enterprise customer. 

Our websites, products and services are designed for enterprise customers and their representatives. We do not offer products or services for use by individuals for their personal, family or household purposes. Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as representatives of the relevant enterprise and not their individual capacities.

Index

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

  • Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
  • Demographic data, such as your city, state, country of residence, postal code, and age.
  • Profile data, such as the username and password that you may set to establish an online account on the Service, date of birth, redemption code, biographical details, photograph or picture, links to your profiles on social networks, interests, preferences, information about your participation in our contests, promotions, or surveys, and any other information that you add to your account profile.  
  • Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via chat features, social media, or otherwise. 
  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
  • Payment data needed to complete transactions, including payment card information or bank account number.
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

  • Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
  • Private sources, such as data providers, social media platforms and data licensors. 
  • Marketing partners, such as joint marketing partners and event co-sponsors.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

  • Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
  • Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails. 

Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:

  • Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place. 
  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications. 
  • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked. 
  • Chat technologies, such as those provided by Salesforce that employ cookies and software code to operate the chat features that you can use to communicate with us through the Service.  Salesforce and other third parties may access and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other personal information you share through online chats for the purposes described in this Privacy Policy.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

  • provide, operate and improve the Service and our business;
  • personalize the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
  • communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
  • communicate with you about events or contests in which you participate;
  • understand your needs and interests, and personalize your experience with the Service and our communications; and
  • provide support for the Service, and respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services. 

Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

  • Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.  
  • Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. 

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

Compliance and protection. We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); 
  • audit our internal processes for compliance with legal and contractual requirements or our internal policies; 
  • enforce the terms and conditions that govern the Service; and 
  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.  

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.  

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.  

Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

  • Technical operation. To allow the technical operation of the Service.
  • Functionality. To enhance the performance and functionality of our services.
  • Advertising. To help our third-party advertising partners collect information about how you use the Service and other online services over time, which they use to show you ads on other online services they believe will interest you and measure how the ads perform.
  • Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.  

Affiliates. Our corporate parent, subsidiaries, and affiliates.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, online chat functionality providers, email delivery, marketing, consumer research and website analytics). 

Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy

Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above. 

Business and marketing partners. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above. 

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Fringe, financing of Fringe, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Fringe as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Your choices 

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.  

Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning.

Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:

  • Browser settings. Changing your internet web browser settings to block third-party cookies.
  • Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies. 
  • Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising. You may be able to exercise that option at the following websites:some text
  • Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs: some text
  • Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes.  

We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above. 

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security 

We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information. 

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.  

Children  

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy 

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

Last updated: 1/8/2024

Privacy Statement

All terms capitalized but not defined herein will have the definition given to such term under GDPR.

This Privacy Policy describes how Fringe processes personal data pertaining to persons that interact with it as website/ platform visitors/ users or direct beneficiaries (meaning how such personal data is: collected; stored; accessed; processed and shared); as well as which are the Legal Basis towards such Processing activities.

This Privacy Policy is provided to you in accordance with the following personal data protection legislation:

  • The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 also known as the General Data Protection Regulation (the “GDPR”), which became enforceable across the EU and the EEA from May 25th, 2018 having replaced the previous Directive 95/46/EC; In Ireland, the national law, which amongst other things, gives further effect to the GDPR, is the Data Protection Act 2018 (‘the 2018 Act’).
  • The Directive 2009/136/EC of the European Parliament and of the Council of 25 November 2009 also known as the ePrivacy Directive, amending the Directive 2002/22/EC on universal service and users’ rights relating to electronic communications networks and services, Directive 2002/58/EC concerning the processing of personal data and the protection of privacy in the electronic communications sector and Regulation (EC) No 2006/2004 on cooperation between national authorities responsible for the enforcement of consumer protection laws;
  • The California Consumer Privacy Act 2018 (the “CCPA”), assembly Bill of the State of California United States of America No. 375, under CHAPTER 55, an act to add Title 1.81.5 (commencing with Section 1798.100) to Part 4 of Division 3 of the Civil Code, relating to privacy and approved by Governor June 28, 2018. And the CPRA (a ballot initiative) that amended the CCPA by including additional privacy protections for consumers passed in Nov. 2020.

The primary goal of processing personal data is to identify authorized users (logged in users) of the Fringe platform and to enable service delivery of the Fringe platform.

Fringe understands that personal data may represent a risk to you if accessed by unauthorized third parties; Fringe has therefore developed a set of policies, operational processes, and mechanisms (technological and human-based) to ensure that the personal data entrusted by you to Fringe will be maintained, handled and shared in a manner that warrants its security, accuracy, confidentiality, and privacy.

Personal data is exclusively processed under the scope and purpose of agreed services between Fringe and a corporate entity facilitating your access to the Fringe platform (the “Corporate Client”) or you, the direct beneficiary (the user who has accepted to continue benefiting from perks and benefits of using the Fringe platform in connection with being an employee of one of Fringe’s Corporate Clients or otherwise).

Each and every data subject maintains full control over the personal data that pertains to them, as well as the Personal Data Processing Activities undertaken by Fringe (as defined under both the GDPR as Data Subject’s Rights and also the rights described under the CCPA).

* * * * *

Applicability

Fringe reserves the right to modify this Privacy Policy at all times by posting an updated timestamped version on its website(s).

* * * * *

Questions Regarding this Policy

All questions or requests regarding the processing of the personal data under our control or processing may be addressed to dataprivacy@fringe.us

Fringe DPO contacts

Mr. Chris Luhrman

Country: US

email: dataprivacy@fringe.us

phone: 8042200775

* * * * *

Fringe Core Activity – Service Catalog and “Legal Basis”

Fringe provides a set of services to other companies as well as natural persons, delivery of which requires “Personal Data Processing Activities”.

Fringe enables Corporate Clients to provide their staff with additional benefits and perks in the form of points toward the purchase of products and services enabled by third parties.

In this scenario, Fringe acts as a Processor whereas the Corporate Client is the Controller, hence the Legal Basis for Fringe to Process the Personal Data consists of a “Contractual Obligation” to the Controller.

When an employee leaves an organization towards which Fringe is delivering its services, Fringe reaches out to that employee asking if he/ she wishes to continue benefiting from the benefits and perks as an independent individual and if that Data Subject accepts, the service continues, whereas if the employee refuses their access to the platform will cease and their data handled in accordance with our Privacy Policy, Terms of Use and our data obligations as a processor.

The Legal Basis in the case of this service is “Explicit Consent”.

* * * * *

What ‘Personal Data’ is subject to processing by Fringe?

Fringe Marketplace service requires that the following categories of Personal Data be processed:

  • Contact Data (e.g. Name; Email; Phone number)
  • Demographic Data (e.g. Date of Birth, Gender)
  • Location Data (e.g. Country; City; State)
  • Professional Information (e.g. Company; Role)
  • Financial Information (e.g. Credit Card Number)
  • Operational (e.g. Attributed benefits; Points; Transaction History)

* * * * *

What Processing is performed to ‘Personal Data’?

Gathering/Collection and Processing

In general Fringe exclusively gathers the Personal Data directly from the Corporate Clients regarding their employee; however, when an employee leaves a Corporate Client but remains a beneficiary, the personal data may be collected from the employee, subject to their consent.

Initially, the personal data is submitted by the Controller (Corporate Client) to Fringe for processing.

In this case the processing is authorized explicitly by the Corporate Client and by the employee using a benefit on the Fringe platform.

When the employee (who has left the organization of the Corporate Client) becomes a direct beneficiary, the Processing is authorized by the employee while making use of the available benefits and perks.

Sharing and Hosting

Fringe is an online platform, which primarily stores its data and information online or digitally.

To process personal data, Fringe relies on certain partners to deliver ervices. Fringe shares only the minimum amount of personal data necessary for those services to be delivered. Fringe shares personal data with the following third-party services providers:

  • Salesforce
  • AWS

Depending on the circumstances, Fringe acts either as the Controller or the initial processor  with these “partners” which act as “processors or sub processors” for Fringe.” The partners will not conduct any “personal data processing activities” activities to information registered, submitted, or conveyed by Fringe unless under the scope of contracted services agreed and documented under an existing Data Processing Agreement (DPA) between the parties governed by applicable personal data protection legislation.

* * * * *

How is the Security, Privacy and Confidentiality of ‘Personal Data’ assured?

Fringe’s technology and processes are configured and monitored in accordance with industry standards. Fringe has reviewed and adopted changes to its operational processes to materially comply with the GDPR’s requirements regarding the protection of personal data.

For details, see Fringe’s Security & Trust page.

* * * * *

 

How long is “Personal Data” maintained?

Fringe retains data according to its services’ lifecycle with the goals a)  to hold “personal data” for no longer than necessary and b) to minimize the risk of deleting information that Fringe needs to provide its services.

Fringe will retain data in accordance with the following general retention schedules:

  • In the case of Fringe’s service coming to an end with a given Corporate Client then Fringe will erase the employee’s data from Fringe’s databases within 90 days.
  • In the case where a user is no longer associated with a Corporate Client and does not provide individual consent, personal data will be managed according to applicable data protection laws and/or Client contractual obligations and requirements.

  • In the case the employee indicates to Fringe that he or she would like to continue using Fringe’s services, Fringe will maintain the employee’s data until the employee terminates his or her account.

Fringe retains the right to retain data longer than the periods listed above if required by applicable law or at the request of a governmental or regulatory authority.

* * * * *

How are “Data Subjects’” rights exercised?

Those users who are no longer associated with a Corporate Client may exercise their data rights directly with Fringe. Those users who are employees of a Corporate Client must contact their employer to exercise such rights.

Under the GDPR, the user has the following set of rights:

[GDPR] Right of access. The right to obtain from the Controller confirmation as to whether his/ her personal data is being processed, and, where that is the case, access to such personal data as well as related information. Fringe will share the personal data over a secure channel, and that (depending on the type of data as well as volume) may imply the need to convey a “password” via an alternative communication channel to the data subject to ensure authorized secure access. Users may exercise this right by reviewing information on Fringe’s website user account area or by submitting a request as detailed below.

 

[CCPA] Right to know and access your personal information – similar to the Right of Access under the GDPR, California resident natural persons have the right to:

 

  • Know the categories of personal information we collect and the categories of sources from which we got the information;
  • Know the business or commercial purposes for which we collect and share personal information;
  • Know the categories of third parties and other entities with whom we share personal information; and
  • Access the specific pieces of personal information we have collected about you.

[GDPR] Right to rectification. The right to obtain the rectification of inaccurate personal data pertaining to that data subject. Users may directly amend existing information on Fringe’s website user account area or by submitting a request as detailed below.

 

[GDPR] Right to erasure. The right to have personal data pertaining to him/ her that is processed by Fringe erased and processing ceases, unless the Controller has a legal duty or a legitimate ground to retain certain data, in which case the data subject will be informed. This right may be exercised by submitting a request as detailed below.

 

[CCPA] Right to deletion – persons who reside in the state of California may, in some circumstances, ask us to delete their personal data/ information. 

We may refuse the exercise of such right if it prevents us from exercising legal defense, it violates a legal obligation, or if there is the risk that by doing so, Fringe would be unable to fulfill a contractual obligation.

[GDPR] The right to restrict processing. Under relevant conditions set out by the law, the right to request and have in place processing restrictions (in scope and purpose) towards personal data that pertains to him/ her. When exercising this right, the user must be specific about which processing activities he or she is requesting be restricted. The Controller must provide feedback to the user either confirming the completion of the request or detailing any potential collateral impact that may derive from implementing the request and asking for additional confirmation prior to implementing the request. This right may be exercised by submitting a request as detailed below.

 

[GDPR] The right to object to processing. A user has the right to object to processing activities under this Privacy Policy. The exercise of this right may also occur where the user wishes to opt-out from an existing Service (and not necessarily canceling the Service). When exercising this right, the user must be specific about which processing activities he or she is requesting be stopped. The Controller must provide feedback to the user either confirming the completion of the request or detailing any potential collateral impact that may derive from implementing the request and asking for additional confirmation prior to implementing the request. This right may be exercised by submitting a request as detailed below.

 

[CCPA] Right to opt out of sales – We do not “sell” your data

 

[GDPR] Right to data portability. The right to receive the personal data pertaining to the user, in a structured, commonly used and machine-readable format as well as the right to transmit such personal data to another controller without hindrance. Fringe will share the personal data over a secure channel. Such transfer may require that Fringe provide a “password” via an alternative communication channel to the user to access the personal data.

 

[GDPR] Right to be informed about a Personal Data Breach. The user has the right to be informed of any unauthorized disclosure or potential disclosure of his or her personal data to unauthorized third parties within 72 hours of its occurrence.

 

[GDPR] Right to lodge a complaint with a supervisory authority. The user has the right to lodge a complaint regarding Fringe’s processing activities to any of the EU Member States data protection Supervisory Authorities.

 

[CCPA] Right to be free from discrimination – A user may exercise any of the above rights without fear of being discriminated against. Fringe is, however, permitted to provide a different price or rate to you if the difference is directly related to the value provided to you by your data.

For any of the above-mentioned CCPA related rights, you may designate an authorized agent to make a request on your behalf. In the request, you or your authorized agent, must provide information sufficient for us to confirm the identity of an authorized agent. We are required to verify that your agent has been properly authorized to request information on your behalf and this may take additional time to fulfill your request.

We will use the information you provide to make your CCPA rights requests to verify your identity, identify the personal information we may hold about you, and act upon your request.

We strongly recommend that you submit the email and postal address that you used when you created accounts, ordered subscriptions, or signed up for a newsletter.  After you submit a CCPA rights request you will be required to verify access to the email address you submitted.  You will receive an email with a follow-up link to complete your email verification process.  You are required to verify your email in order for us to proceed with your CCPA rights requests.  Please check your spam or junk folder in case you can’t see the verification email in your inbox.

Any EU user may exercise his/ her rights under “GDPR” by reaching out to Fringe’ “DPO'' through the email address dataprivacy@fringe.us or via the appropriate representative listed below. If you have any questions, complaints or wish to exercise your rights under “GDPR”, indicate so in your message:

  • Purpose: Question; Complaint; Exercise of the “Data Subject’s” rights under “GDPR”
  • WHAT triggered your need to contact us?
  • WHEN did the root cause which triggered the need to contact us took place?
  • If a Member, your Member ID, or if not a mobile phone number or alternative personal email address so we may proceed with a two-factor authentication process.

Why the need to provide alternative personal contact?

Under “GDPR” only the “data subject” may exercise his or her rights. As a result, Fringe must ensure and document that the data subject or his or her legal representatives are the ones interacting with the company.

EU Representative
Osano International Compliance Services Limited
ATTN: NZ77
3 Dublin Landings
North Wall Quay
Dublin 1
D01C4E0

UK Representative

Osano UK Compliance LTD

ATTN: NZ7742

46 Fountain Street

Belfast Antrim

BT1-5EF

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