When we talk about ‘you’, ‘user’ or ‘your’ in our terms and conditions, we mean you, the visitor to or user of our online services.
We take your privacy seriously and we have drafted this policy to let you know what information we collect about you, what we do with it, how we store it and what your rights are.
'Personal information' is information that directly identifies you, such as your name and email address, or data that could be used, on its own or in combination with other data, to identify you.
In general, we only use your personal information for the delivery of our services and to send you information about our services. We never sell or giveaway your personal information.
You can browse our online services anonymously. However, if you request information or sign up for or purchase a subscription, you will need to identify yourself and at that point we will start collecting your personal information. If you do not give personal information to us, it will affect our ability to provide you with requested information or to deliver our products or services.
Collecting personal information
At all times we aim to only collect the minimum information we need for the services we are providing. For example, if you sign up to use our services, we will collect and use your email address, business details and key contact details, we need this information to enable your employees to use our services.
As you would expect, the more involved you are with us, the more information about you we will collect.
The main way we collect information about you is when you give it to us and this can happen in a variety of ways.
We may process the following categories of personal information about you:
- Communication data: which includes any communication that you send to us. This might be when you request a Proposal, join our mailing list or when you contact us through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. If you sign in using social media, we receive (by your consent) additional information such as your profile picture and social profile ID. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is to reply to communications sent to us, keep records and to establish, pursue or defend legal claims, each of which is a legitimate business interest.
- Customer Data: which includes data you give to us when you purchase goods and/or services from us. This will include basic information about you and also the information we require for billing purposes such as a name, title, billing address, delivery address, email address, phone number, contact details, purchase order details and your payment card details (last digits only). We process this data to supply the goods and/or services you have expressed an interest in or purchased and to keep records of those transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into a contract and our legitimate business interest of keeping records for accounting purposes.
- User Data: which includes data about how you use our website and any online services together with any data that you post for publication on our website (eg. testimonial) or through other online services. We process this data to operate our online services and ensure relevant content is provided to you, to ensure the security of our online service, to maintain back- ups of our online services and/or databases and to enable publication and administration of our online services and business. Our lawful ground for this processing is to properly administer our online services and our business, each of which is a legitimate business interest.
- Technical Data: which includes data about your use of online services such as your IP address, your login data, details about your browser, length of visit to pages, page views and navigation paths, details about the number of times you use our online services, time zone settings and other technology on the devices you use to access our online services. The source of this data is from our analytics tracking system. We also use our own cookies for functions such as checking if you are logged in and which products you have access to. We process this data to analyse your use of our online services, to administer and protect our business, to deliver relevant content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is the proper administration of our online services and business and to grow our business and decide our marketing strategy, each of which is a legitimate business interest.
- We may also use your personal information to carry out some automated decision making about you. For instance, our email manager may monitor which mails you open and use this information to automatically manage future emails you receive. Our lawful ground for this processing is to study how customers use our products/services and to grow our business, which are legitimate business interests.
Collecting information from third parties
As discussed above, we collect personal information about you when you give it to us and when it is collected by our website however we may also collect personal information that is given to us or available to us by a third party (for example, information that you have made available on a public platform like a discussion site).
We may receive data from third parties such as analytics providers and advertising networks like Google and LinkedIn.
This information forms part of the personal information described in this policy. We will not intentionally collect personal information that is unintentionally disclosed.
Collecting sensitive information
We do not intend to collect sensitive information about you and request you never disclose information about your health, racial or ethnic origin, political opinions, religious beliefs or sexual orientation on our online services.
Our services are not designed to be used by minors under the age of 18 and we do not intend to collect information about minors. By providing us with your data, you warrant to us you are over the age of 18, or the business user of our online services has identified you as a staff member authorised to use our online services.
If you provide us with a review or testimonial, you give us your consent to use your name, likeness, web address, product you are reviewing and the date of service delivery to be displayed on our online services or in our other marketing material, together with the content of the testimonial that you provide. We may store and/or use your review for as long as the information is relevant to our business. We process this information based on your consent which you may withdraw. If you withdraw your consent, we may still use your testimonial however your personal information will be anonymised.
Our lawful ground of processing your personal data to send you marketing communications is either your express consent or to grow our business, which is a legitimate business interest. Sometimes we may recommend sharing your information with a third party for their marketing or other purposes. Before we share your personal data with any third party, we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any emails sent to you. You can also email us at email@example.com to request your details be removed from our marketing list.
If you opt out of receiving marketing communications, this opt-out does not apply to personal data provided for other transactions such as purchases.
Social Networking Services and links to other websites
You can connect with us via our social media pages for example on Linkedin. We may also provide links to other websites or use social networking services to communicate with the public about our work.
When you communicate with us using these services we may collect your personal information. The social networking service will also handle your personal information for its own purposes and have their own privacy policies. You should become familiar with the privacy policies of any service you use.
We use a range of tools provided by third party service providers and search engine browsers to collect or view access and traffic information for statistical, reporting and maintenance purposes. Third party providers have their own privacy policies. We may also use tracking pixels, cookies and session tools to improve your experience when accessing our online services.
The data collected by cookies does not usually identify you but may be combined with other information to identify you. If we identify you using information from cookies, we may use that information to track how you use our online services and send you information more specific to your needs, or to invite you to purchase our services.
The kind of information that can be collected includes:
- device specific information such as mobile network information
- server logs including your IP address, the times you use our services and system activity
- location information including IP address and Wi-Fi access points
We use the information to help to track your use of our online services to improve your user experience and the quality of our services.
Use and disclosure of personal information
In summary, as a legitimate business interest, the personal information we collect about you is used:
- to verify your identity
- to enable you to use our services
- to process orders, subscriptions and enquiries
- to provide you with information about products and services that may interest you
- to provide you with personalised service or special opportunities
- to allow you to participate in interactive features of our online services
- to facilitate our internal business operations
- to improve our products or services and in planning new products or services
- to monitor compliance with our terms and conditions
With your consent or at your request we may:
- Share your contact information with third party organisations who offer products or services that may be of interest to you (if you agree to receive such information)
We may also disclose your information to:
- Other companies in our group who provide services to us.
- Third party payment platforms if there is a dispute over a payment. For example, if a bank contacts us regarding a dispute over a payment, we will provide the bank with information such as IP address, subscription and activity linked to the billing details on our system to allow the payment dispute to be resolved.
- Professional advisers including accountants, lawyers, bankers, auditors and insurers.
- Government bodies that require us to report processing activities.
- Third parties where we are required to in accordance with the law. We reserve the right to fully co-operate with any law enforcement authorities or court orders requiring or requesting us to disclose the identity or other usage details of any user of our online services, or in accordance with a properly executed court order, or as otherwise required to do so by law.
Mandatory data reporting
If any of your personal information is lost, accessed or disclosed by us, whether intentionally, unintentionally or through no fault of otso we will comply with mandatory data breach notification requirements.
We are required to notify any affected person within thirty (30) days if the loss or disclosure of data is likely to result in serious harm to that person.
We will provide you with the opportunity to opt-in to receive information about our products or services. You can change your preferences at any time using the unsubscribe options in the emails you receive.
If you would like to delete your account with us, you may do so by contacting us at firstname.lastname@example.org and requesting your account and non-transaction data be deleted. Please note that this will not delete all personal information from our system as we retain your information in other areas. For example, we will still retain your product purchase history.
If you continue to receive communications you have unsubscribed from, please contact us via email at email@example.com and we will remedy the problem.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, and if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including contact, identity, financial and transaction data) for some time even after they stop being customers.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Third Party Links
Our online services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Accessing and correcting your personal information – Your legal rights
Under data protection laws you have rights (depending on your country of origin) in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org for assistance.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. For record keeping purposes, we will record and store all information exchanged during an exercise of your rights under this clause.
We try to respond to all legitimate requests within thirty (30) days. Occasionally it may take us longer than thirty (30) days if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you request to have your information erased (also known as the right to be forgotten), we will, if appropriate, delete your personal information from our active business operating system. Your personal information will however continue to be stored within our backup(s) as we are unable to delete specific items from our backup. It will be deleted at the next scheduled backup deletion. We will keep a log of your request to be forgotten so that, should our backup be used to restore our operating system while your personal information is still stored, your personal information will again be removed from our active system upon restoration.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office in your country. For instance, in Australia, contact the Privacy Commissioner Office at www.oaic.gov.au. We would be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
[last updated August 2019]
This policy explains how we do that.
What are cookies?
Cookies are small text files a website may put on your computer or mobile device when you first visit a site or page. The cookie helps that website, or another website, recognize your device the next time you visit. Web beacons or other similar files do the same thing. We use the term “cookies” in our terms and conditions to refer to all files that collect information in this way. Cookies can serve many functions. For example, they may help us remember your username and preferences, analyse how well our website is performing, or even allow us to recommend content we believe will be most relevant to you.
Certain cookies contain personal information. For example, if you select “remember me” when logging in, a cookie will store your username. Most cookies won’t collect information that identifies you personally and will instead collect more general information such as how you arrive at and use our website or your general location.
If you use your browser settings to block all cookies (including essential cookies) you may not be able to access all parts of our website.
What sort of cookies does otso use?
Essential Cookies. Some cookies are essential for the operation of our website. For example, some cookies allow us to identify a user and ensure they can access certain areas. If a subscriber opts to disable these cookies, they will not be able to access all the content they require.
Performance Cookies. We use other cookies to analyse how our visitors use our websites and to monitor website performance. This allows us to provide a high-quality experience by customizing our offerings and quickly identifying and fixing any issues that arise. For example, we might use performance cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages. We might also use these cookies to highlight articles or site services that we think will be of interest to you based on your use of the website.
Functionality Cookies. We use functionality cookies to allow us to remember your preferences. For example, cookies save you the trouble of typing in your username every time you access the site. Cookies recall your customization preferences. We also use functionality cookies to provide you with enhanced services such as allowing you to watch a video online or comment on a blog (if applicable).
Cookies can be:
Session Cookies. These are only stored on your device during your web session and are automatically deleted when you close your browser. For example, there may be a session ID set that allows you to browse our website without having to log in to each individual page.
Persistent Cookies. A persistent cookie is stored on your device and remains there when you close your web browser. For example, we use a cookie to remember your log-in information. The cookie is set by our website when you indicate you would like your user information remembered and is read by our website the next time you visit our website.
Advertisers sometimes use their own cookies to provide you with targeted advertising. For example, advertisers may use a profile they have built on sites you have previously visited to present you with more relevant advertisements. We believe our users prefer to see advertisements that are more relevant to their interests.
If you are based in the European Union and would like to learn more about how advertisers use these types of cookies or how to choose not to receive them, please visit www.youronlinechoices.eu.
Can you block cookies?
As discussed above, you can set your browser to not accept cookies however If you choose to disable cookies, you may find that certain sections of our online services do not work properly.
To find out how to opt out of tailored advertising and Google tracking please check the options available here - https://adssettings.google.com/authenticated and https://tools.google.com/dlpage/gaoptout.
Do we track whether you open our emails?
Our emails may contain a campaign-unique web beacon pixel to tell us whether our emails are opened and to verify any click-throughs to links or advertisements within the email. We may use this information for purposes including to determine which of our emails are more interesting to users, to query whether users who do not open our emails wish to continue receiving them, and to inform our advertisers (in aggregate) how many users have clicked on their advertisements (if applicable). The web beacon pixel is deleted when you delete the email. If you do not wish the pixel to be downloaded to your device, you can elect to receive emails from us in plain text rather than HTML.