Privacy Policy

1. Introduction

Okon Recycling (referred to as "we," "us," "our") is committed to protecting your privacy. This Privacy Policy describes how we collect, use, disclose, and protect your personal information when you use our customer-loyalty / rewards app (the "App"), and how you may access and control such information. By using the App, you agree to the collection and use of information in accordance with this policy.

2. Scope

This policy applies to all users of the App, including in, but not limited to, scrap material sellers, commercial customers, public-recycling participants, and any other user who enrolls in our loyalty program via the App. It covers both mobile and web versions of the App.

3. Information We Collect

We may collect the following types of information:

a) Personal Information You Provide

• Name, address, email, and phone number.
• Company or business name, if applicable, and tax ID when required by industry or transaction.
• Account credentials, such as user name and password.
• Payment information if you use the App to redeem rewards or make deposits or withdrawals.
• Transaction history, such as scrap metal brought to our facility, pounds processed, and reward points earned or redeemed.
• Location data, if you permit the App to access location services, to facilitate the appropriate scrap-yard branch or container pickup.
• Profile information, such as preferences and communication choices.

b) Automatically Collected Information

• Device information, including device type, operating system, mobile network, and device identifiers.
• Usage information, including app session times, pages or screens visited, and interactions within the App.
• Log data, such as IP address, timestamps, and referral URL.
• Geolocation, if enabled and collected with appropriate consent.

c) Information From Third Parties

• We may obtain information about you from third-party sources, for example public records, credit-check providers, scrap metal industry compliance databases, or aggregator services. We may merge that information with data we collect ourselves.

d) Special Category / Sensitive Data

• We do not intentionally collect sensitive personal data, such as race, religion, or biometric data, unless explicitly required for compliance, such as scrap-metal industry regulatory recordkeeping. If so, we will obtain your explicit consent.

4. How We Use Your Information

• To operate, maintain, and provide the App features and our loyalty and rewards program.
• To enroll you as a member, provide you with an account, and evaluate your eligibility for rewards.
• To track loyalty points, transactions, redemptions, and manage your account.
• To provide customer service and respond to inquiries or support requests.
• To communicate with you by email, SMS, or push notifications about your account, program changes, offers, updates, and promotions.
• To facilitate payment processing, rewards redemption, and deposit or withdrawal of earned funds, if applicable.
• To comply with legal, regulatory, audit, and safety obligations applicable to the scrap recycling industry under Texas law, including recovery of traceability data and recordkeeping of materials received.
• For marketing and analytics, including analyzing usage trends, improving the App, and delivering tailored offers. You may opt out of certain marketing communications as described in Section 9.
• To detect, prevent, and address fraud, security issues, unauthorized access, and other misuse of the App.
• For business purposes such as mergers, acquisitions, sale of assets, or corporate restructuring, subject to Section 8.

5. Legal Basis for Processing (where required)

Where required under applicable law, such as GDPR frameworks or state privacy regimes, our legal bases for processing your personal data include:

• Performance of a contract with you, including providing the loyalty program.
• Legitimate interests, including improving our service, protecting our business, and marketing.
• Your consent, such as for location data or push notifications.
• Compliance with legal obligations, including regulatory obligations in Texas relating to scrap metal, environmental safety, and recordkeeping.

6. Sharing Your Information

• With our service providers, contractors, and agents who help us operate the App, process transactions, deliver rewards, conduct analytics, and provide support, subject to confidentiality obligations.
• With affiliates and other companies in the recycling supply chain where necessary to complete the scrap transaction or, if you participate via a business, for settlement reports.
• With regulatory authorities or law enforcement when required by law, including Texas laws relating to scrap metal purchasing records, payments over thresholds, identity verification, or environmental regulations.
• With third parties in connection with a business transaction, such as a merger, sale, or asset transfer. In that case, we will use commercially reasonable efforts to require that the transferee handle your data under terms consistent with this Privacy Policy.
• Aggregated or de-identified data that cannot reasonably identify you individually may be shared for marketing or analytics purposes.

7. Data Retention

We will retain your personal information for as long as necessary to fulfill the purposes set out in this policy. This includes retaining data to comply with legal and regulatory obligations under Texas and federal law, including recordkeeping obligations under the Texas Business & Commerce Code and regulations applicable to the scrap metal industry. When we no longer require your data, we will securely delete or anonymize it.

8. International Transfers

Your information may be transferred to, and stored or processed in, locations outside your residence, including outside the United States. When we do so, we will protect your information as described in this policy and ensure safeguards such as standard contractual clauses where required by law.

9. Your Rights and Choices

Depending on your jurisdiction and applicable law, you may have the following rights:

• Access: you can request a copy of the personal information we hold about you.
• Correction: you can ask us to correct inaccurate or incomplete information.
• Deletion: you can request deletion of your data, subject to our retention obligations such as regulatory recordkeeping.
• Restriction of processing: you can request that we restrict how we use your data.
• Portability: you may request your data in a structured, machine-readable format.
• Opposition or opt-out: you can object to certain processing, such as direct marketing.
• Withdrawal of consent: if you provided consent, such as for location tracking, you may withdraw it at any time, though that may limit App functionality.
• Opt-out of marketing communications: you may unsubscribe from promotional emails, SMS, or push notifications.
• To exercise your rights, please contact us as described in Section 12.

10. Children's Privacy

Our App is not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If you are under 13, do not use the App or provide us with personal information. If we learn we have collected personal information from a child under 13, we will delete it as required by law, including the Children's Online Privacy Protection Act (COPPA).

11. Security

We implement reasonable physical, organizational, technical, and administrative safeguards to protect your personal information from unauthorized access, unlawful processing, and accidental loss or destruction. However, no system can be 100% secure, and we cannot guarantee absolute security of your data. You accept the inherent security risks of using the internet and an app.

12. Contact Us

If you have any questions about this Privacy Policy, to exercise your rights, or to file a complaint, you may contact:

Please allow us reasonable time to respond to your request.

13. Accessibility / ADA Compliance

We are committed to making the App and our website accessible to people with disabilities. We endeavor to follow industry best practices and applicable accessibility standards, including the Americans with Disabilities Act of 1990 (ADA), Section 508, and WCAG 2.1, to help ensure equal access. If you experience difficulty accessing the App or website, or need assistance using features of the loyalty program, please contact us as described in Section 12 and we will work with you to provide appropriate accommodations.

14. Changes to this Policy

We may revise this Privacy Policy from time to time. If we make material changes, we will notify you via the App or by email, and update the Last Updated date at the top of this page. Your continued use of the App after those changes constitutes your acceptance of the updated policy.