This Security and Privacy Policy, together with the Foamma.com Terms and Conditions posted on our Website set forth the general rules and policies governing your use of our Website. Depending on your activities when visiting our Website, you may be required to agree to additional terms and conditions.Foamma.com (“Foamma”) keeps this Security and Privacy Policy posted on its website and you should review it frequently, as it may change from time to time without notice. Any changes will be effective immediately upon the posting of the revised Security and Privacy Policy.
WHEN YOU ACCESS OUR WEBSITE, YOU CONSENT TO THE TERMS OF THIS SECURITY AND PRIVACY STATEMENT. IF YOU DO NOT AGREE TO THIS SECURITY AND PRIVACY STATEMENT, OR TO ANY CHANGES WE MAY SUBSEQUENTLY MAKE, IMMEDIATELY STOP ACCESSING OUR WEBSITE.
SECURITY POLICY
As Foamma’s security policy is a high level definition of secure consistent behavior, it is meaningless to claim an entity is “secure” without knowing what “secure” means. The bottom line is simple – what is shared with our company, stays in our company through multiple secure levels.
Virus Prevention Policy
The willful introduction of computer viruses or disruptive/destructive programs into Foamma’s environment is prohibited, and violators may be subject to prosecution. All desktop systems that connect to Foamma network must be protected with an approved, licensed anti-virus software product that it is kept updated according to the vendor’s recommendations. All servers and workstations that connect to the network and that are vulnerable to virus or worm attack must be protected with an approved, licensed anti-virus software product that it is kept updated according to the vendor’s recommendations. Headers of all incoming data including electronic mail must be scanned for viruses by the email server where such products exist and are financially feasible to implement. Outgoing electronic mail should be scanned where such capabilities exist. Where feasible, system or network administrators should inform users when a virus has been detected. Virus scanning logs must be maintained whenever email is centrally scanned for viruses.
Intrusion Detection Policy
Intruder detection must be implemented on all servers and workstations containing data classified as high risk. Operating system and application software logging processes must be enabled on all host and server systems. Where possible, alarm and alert functions, as well as logging and monitoring systems must be enabled. Server, firewall, and critical system logs should be reviewed frequently. Where possible, automated review should be enabled and alerts should be transmitted to the administrator when a serious security intrusion is detected. Intrusion tools should be installed where appropriate and checked on a regular basis.

Internet Security Policy
All connections to the Internet must go through a properly secured connection point to ensure Foamma’s network is protected when the data is classified high risk. All connections to the Internet should go through a properly secured connection point to ensure the network is protected when the data is classified confidential.
System Security Policy
All systems connected to the Internet should have a supported version of the operating system installed. All systems connected to the Internet must be current with security patches. System integrity checks of host and server systems housing high risk Foamma data should be performed.
Acceptable Use Policy
Foamma must have a policy on appropriate and acceptable use that includes these requirements: Foamma computer resources must be used in a manner that complies with OCG, Inc. policies and State and Federal laws and regulations. It is against Foamma policy to install or run software requiring a license on any Foamma computer without a valid license. Use of the Foamma’s computing and networking infrastructure by Foamma employees unrelated to their positions must be limited in both time and resources and must not interfere in any way with Foamma functions or the employee’s duties. Use of Foamma resources for personal profit is not permitted except as addressed under other OCG, Inc. policies. Decryption of external or internal passwords is not permitted, except by authorized staff performing security reviews or investigations. Use of network sniffers shall be restricted to system administrators who must use such tools to solve network problems. Auditors or security officers in the performance of their duties may also use them. They must not be used to monitor or track any individual’s network activity except under special authorization as defined by campus policy that protects the privacy of information in electronic form.
PRIVACY POLICY
Foamma recognizes that privacy is important. This Privacy Policy applies to all of the products, services, and websites owned and offered by Foamma. Foamma adheres to the US Safe Harbor Privacy Principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement. We do employ tracking technologies such as pixels, and end-user website activity.
Information we collect and how we use it: We offer a number of services that do not require you to register for an account or provide any personal information to us, such as Foamma articles and information on the products and services we sell. In order to provide our full range of services, we may collect the following types of information:
Information you provide – When you sign up for a Foamma account or other Foamma service or promotion that requires registration, we ask you for personal information (such as your name, email address and an account password). For certain services, we also may request credit card or other payment account information which we maintain in encrypted form on secure servers. We may combine the information you submit under your account with information from other Foamma services or third parties in order to provide you with a better experience and to improve the quality of our services. For certain services, we may give you the opportunity to opt out of combining such information.
Cookies – When you visit Foamma, we send one or more cookies – a small file containing a string of characters – to your computer or other device that uniquely identifies your browser. We use cookies to improve the quality of our service to you, our valued customer, including for storing user preferences, improving search results, and tracking user trends, and for targeted advertising purposes. Our site users are able to opt out of targeted, personalized, advertising. On ads served by AdRoll, you can look for an AdChoices logo (the blue triangle) in the corner of the ad. For more information please see AdRoll’s’ privacy notice here. You may also visit the DAA’s Consumer Choice page, which allows online users to conveniently opt out from Choice Page participating companies’ collection of Web viewing data over time and across unaffiliated sites for IBA and other applicable uses under the Principles.
Residents of California can read our updated privacy notice here according to California Consumer Privacy Act (“CCPA”)
Log information – When you access Foamma website, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.
Consent To Our Communication With You By E-Mail – By establishing a registered account with us, and/or each time you make a purchase through our site, you grant permission for Foamma or OCG, LLC to contact you at your e-mail address. To stop receiving our monthly newsletters, promotional/marketing, or special announcement e-mails follow the opt-out procedures set forth at the bottom of each email sent to you by our company.
Other sites – This Privacy Policy applies to Foamma website, products, and services only. We do not exercise control over external links from our site to other third-party sites. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you no related to Foamma.
Foamma only processes personal information for the purposes described in this Privacy Policy and/or the supplementary privacy notices for specific services. In addition to the above, such purposes include:
Providing our products & services, including the display of customized content and product presentations;
Auditing, research and analysis in order to maintain, protect and improve our products & services;
Ensuring the technical functioning of our website;
Protecting the rights or property of Foamma or our users; and
Developing new services.
Foamma processes personal information on our servers in the United States of America.
Choices for Personal Information
When you sign up as a registered user on Foamma that requires registration, we ask you to provide personal information. If we use this information in a manner different than the purpose for which it was collected, then we will ask for your consent prior to such use.
If we propose to use personal information for any purposes other than those described in this Privacy Policy and/or in the specific service privacy notices, we will offer you an effective way to opt out of the use of personal information for those other purposes. We will not collect or use sensitive information for purposes other than those described in this Privacy Policy and/or in the supplementary service privacy notices, unless we have obtained your prior consent.
Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Foamma features, products, and services may not function properly if your cookies are disabled. You can decline to submit personal information to any of our services, in which case Foamma may not be able to provide those services to you.
Information Sharing
Foamma only shares personal information with other companies or individuals outside of Foamma in the following limited circumstances:
We have your prior written consent – electronically via email or registration. We require opt-in consent for the sharing of any sensitive personal information.
We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.
We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of Foamma, its users or the public as required or permitted by law.
If Foamma becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will ensure the confidentiality of any personal information involved in such transactions and provide notice before personal information is transferred and becomes subject to a different privacy policy.

Please contact us at the address below for any additional questions about the management or use of personal data.
Information Security
We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.
We restrict access to personal information to Foamma employees, suppliers, manufacturers, and agents who need to know that information in order to fulfill your order or to develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
Data Integrity
Foamma processes personal information only for the purposes for which it was collected and in accordance with this Privacy Policy or any applicable service-specific privacy notice. We review our data collection, storage and processing practices to ensure that we only collect, store and process the personal information needed to provide or improve our services or as otherwise permitted under this Policy. We take reasonable steps to ensure that the personal information we process is accurate, complete, and current, but we depend on our users to update or correct their personal information whenever necessary.
Accessing and updating personal information When you use Foamma website, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask our online customers to identify themselves and the information requested to be accessed, corrected or removed before processing orders.
Enforcement
Foamma regularly reviews its compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this Privacy Policy or Foamma’s treatment of personal information by writing to us at:
OCG, LLC c/o Foamma
9560 Owensmouth, Ave Los Angeles, California
Tel: 800-4604828
When we receive formal written complaints at this address, it is Foamma’s policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between Foamma and an individual.
Changes to Our Privacy Policy
Please note that this Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent, and we expect most such changes will be minor. Regardless, we will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). If you have any additional questions or concerns about this Privacy Policy, please feel free to contact us any time through this web site or at:
OCG, c/o Foamma
9560 Owensmouth, Ave Los Angeles, California
Tel: 800-4604828