We collect personal data and other data through:
- Social media pages (collectively, our “Social Media Pages”).
- Marketing campaigns designated to company's contacts.
Collectively, we refer to the Website, the marketing campaigns and our Social Media Pages, as the “Online Services”.
You should be aware that the collection of certain Personal Data is subject to receiving your consent.
However, if you do not provide us with the Personal Data that we request, or prohibit us from collecting such data, we may not be able to provide you with our Services.
“Personal Data” means data that identifies you as an individual or relates to an identifiable individual. We collect Personal Data, such as:
- Contact and Account information: e.g., your full name, email address, password, mailing address, phone number, date of birth, ID number, governmental-issued ID.
- Geo-Location information: e.g., your country, preferred language and other location based-information.
- Payment information: e.g., your credit card number or your payment account details.
- Communication information: General information you have submitted to us via support or other requests.
- Usage Information: e.g., technical information about your interaction with us, IP address, unique device identifiers and information.
“Other Data” means data that does not reveal your specific identity or does not relate to an individual directly. We collect Other Data, such as, browser and device data including data collected through cookies, aggregated data relative to your geographical position and responses to promotional offers (landing pages) and surveys.
In some instances, we may combine Other Data with Personal Data (such as combining your name with your location). If we do so, we will treat the combined data as Personal Data as long as it is combined.
A "cookie" is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and may be used for various different purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and the Services quicker, easier and smoother. Cookies, by themselves, do not expose your personally identifiable information unless you choose to provide this information to us (by, for example, registering for one of our services). However, once you choose to provide the site with your personally identifiable information, this information may be linked to the data stored in the cookie.
When you use or access our Services, we use the following categories of Tracking Technologies:
- Strictly Necessary Tracking Technologies – these Tracking Technologies are automatically placed on your computer or device when you access our Online Services or take certain actions on the website. These Tracking Technologies are essential to enable you to navigate around and use the features of our services. We do not need to obtain your consent in order to use these Tracking Technologies;
- Tracking and Advertising Tracking Technologies – these Tracking Technologies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The Tracking Technologies remember the websites you visit and that information is shared with other parties such as advertisers and/or publishers. Publishers, advertisers, and third-party ad networks may also utilize Tracking Technologies or similar technologies to deliver ads and monitor the performance of such ads. The collection of information through Tracking Technologies by such third parties will be governed by their own privacy policies/cookies policies and principles, which the Company does not control;
- Functionality Tracking Technologies – these Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged-in) and support other features of our Services;
- Performance Tracking Technologies – these Tracking Technologies collect information about your online activity (for example the duration of your visit on our Services), including behavioural data and content engagement metrics. These Tracking Technologies are used for analytics, research and to perform statistics (based on aggregated information).
- Session Tracking Technologies - these Cookies are stored only temporarily during a browsing session and are deleted from your device when you close the browser. We use Session Cookies to support the functionality of the site and to understand your use of the site, for example which pages you visit, which links you use and how long you stay on each page.
There are various ways in which you can manage and control your Tracking Technologies settings. Please remember that, by deleting or blocking Tracking Technologies, some of the features of the Services may not work properly or as effectively.
- Below are some links to some commonly used web browsers. Information about cookies is usually found in the "Help" section of the web browser.
For other browsers, please consult the documentation that your browser manufacturer provides.
- Mobile Devices - You can-opt out of certain types of interest-based advertising (or “cross-app” advertising), by accessing the “settings” on your device:
- If you're using an Apple device you can configure your device to limit ad tracking to by clicking on "settings" > "privacy" > "advertising" and toggling "limit ad tracking" to ‘on.’
- If you're using an Android device you can opt out of most app-based tracking for advertising by opening the "Google Settings" app on your device, selecting "Ads", and then selecting the option to opt-out of interest-based ads.
Please note that the above information may change when the above manufacturers updates their systems. Also note, that your device may use another platform, not described above. In that case, please consult the manufacturer documentation for further instructions.
- You can also turn off certain third party targeting and advertising cookies by visiting the following link: Network Advertising Initiative.
We collect Personal Data and Other Data in a variety of ways:
- Online Services. We collect Personal Data when you register to OTP's website, communicate with us by email, send a request, or otherwise connect with us through social media pages, or sign up for a newsletter or participate in marketing campaigns and/or surveys.
- Offline channel. We collect Personal Data when you visit in OTP's exhibitions and when you attend promotional events that we host or in which we participate.
- Automatic Information: When you use or interact with our website and/or use other online services, we receive and store information generated by your activity and information automatically collected from your browser or mobile device. For example, like many websites, we obtain certain information when your web browser accesses our website including your IP address, device type, browser type, operating system, sites that were accessed during your visit, pages viewed and access dates. This information helps us to communicate with our customers and provide them with our services and products.
- Aggregated Data. We may aggregate data that we collect and this aggregated data will not personally identify you or any other user.
Privacy laws require us to have a valid lawful basis in order to process your Personal Data. This section explains for what purposes we may use your Personal Data and outlines the legal bases that underlie our usage.
We use Personal Data and Other Data for one or more of the purposes detailed below:
- To provide OTP's online platforms services and functions and to administer your use of OTP online platforms.
- To ensure an effective performance and management of our business relationship with you, including facilitating payments.
- To verify your identity.
- To answer and fulfill your specific requests.
- Communicating with Business Partners about products, services of OTP we think may be of interest to you including sending you important information regarding our website, changes in our terms, conditions, policies, or other administrative issues. (e.g. by responding to requests or providing you with technical information about purchased products);
- Planning, performing and managing the (contractual) relationship with Business Partners, e.g. by performing transactions and orders of products or services, processing payments, performing accounting, auditing, billing and collection activities, arranging shipments and deliveries, facilitating repairs and providing support services;
- Administrating and performing customer surveys, marketing campaigns, market analysis, sweepstakes, contests, or other promotional activities or events.
- Maintaining and protecting the security of our products, services and websites, preventing and detecting security threats, fraud or other criminal or malicious activities.
- Ensuring compliance with legal obligations (such as record keeping obligations), complying with legal and regulatory requirements or demands in accordance with applicable law, regulations, or other legal processes including exerting controls.
- We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication (such as groups, meetings and events). The correspondence data may be processed for the purposes of communicating with you and record-keeping.
- For our internal business purposes such as: developing new products, enhancing the website, improving our services, identifying usage trends and visiting patterns, determining the effectiveness of our promotions, evaluating Third Parties performance, predicating our yield and occupancy etc.
- We may use some or all of the Personal Data and Other Data in order to perform certain statistical calculations, some of which may be presented on the website or other services; In any case, these calculations shall not include any personally identifiable information or details.
The legal basis for processing your Personal Data is made up of one or more of the following reasons:
- Your consent.
- Providing the Services.
- Compliance with applicable laws, regulations or other legal process.
- Legitimate Business Interests pursued by OTP.
We share your Personal Data as descried below:
- With subcontractors and third party service providers who assist us in providing our Services, these include but are not limited to:
- Mirage – provides provide IT services to OTP and processes such data only for the purpose of such services (e.g., hosting or IT maintenance and support services).
- We use third party for fulfilment and payment services. Therefore personal data may be shared with the third party for the matter of transactions.
- Our marketing and advertisement partners, to provide you with more-relevant ads on our site and to encourage you to return to our site including taking part in our exhibitions.
- Companies within our group and other affiliated companies.
- We may share your data if we enter into a business transaction such as an investment, merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires some or part of our assets as part of such a transaction may continue to use your data in accordance with the terms of this Policy.
- We may disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
- We may also disclose Personal Data as we believe to be necessary or appropriate: (a) to enforce our terms and conditions; (b) to protect our operations; (c) to protect the rights, privacy, safety or property of OTP, of you or of others; and (d) to allow us to pursue available remedies or limit the damages that we may sustain.
As a general principal, data processing is held within the UK or the European Union (“EU”) including by our third parties.
Despite the general principal stated above, some information might be held on a cloud outside the borders of the EU. The operator of such services is responsible for compliance with the General Data Protection Regulations provisions. In this specific case, be sure that we will verify that appropriate measures have been put in place to ensure that your Personal Data is treated with an adequate level of protection (in particular through standard contractual clauses of the European Commission and our internal company rules).
Sometimes the recipients to whom OTP transfers your personal data are located in countries in which applicable laws do not offer the same level of data protection as the laws of your home country.
In such cases, OTP takes measures to implement appropriate and suitable safeguards for the protection of your personal data.
- Data Protection Rights.
This section addresses the specific rights applying to residents of the UK, EU or residents of another jurisdiction that affords the below rights.
You may request to:
- Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.
- Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.
- Request rectification of your Personal Data that is in our control.
- Request erasure of your Personal Data.
- Object to the processing of Personal Data by us.
- Request to restrict processing of your Personal Data by us.
- Lodge a complaint with a supervisory authority.
Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. Users outside the EU are welcome to contact us for any questions or requests at the details below.
We implement reasonable administrative, organizational and technical safeguards and security measures to protect Personal Data from unauthorized access, disclosure, destruction or alteration, accidental loss, misuse or damage. We regularly review and monitor such safeguards and security measures.
When disclosure of data to third parties is necessary and authorized, we ensure that these third parties guarantee the same level of data protection as that offered to them by us and requires contractual guarantees so that the data are exclusively processed for the purposes you have previously accepted, and with the required confidentiality and security.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contact Us” section, below.
To the extent permissible by applicable law, we will retain your Personal Data for such period as necessary to satisfy or to fulfill the following:
- The purposes for which that Personal Data was provided.
- An identifiable and ongoing business need, including record keeping.
- A requirement to retain records that may be relevant to any notified regulatory investigations or active legal proceedings.
- Comply with any applicable law, regulation, legal process, including, without limitation, court orders and/or compulsory disclosures required by governmental authorities.
- Fulfill legitimate interests of OTP and third parties, such as, defend in cases of legal procedures etc.
- Sensitive Data
Unless specifically requested, we recommend that you don't send us, or disclose, on or through the Services or otherwise, to us, any Sensitive Personal Data (data related to racial or ethnic origin, political opinions, religion, ideological or other beliefs, health, biometrics or genetic characteristics, criminal background, trade union membership, administrative or criminal proceedings and sanctions).
OTP does not knowingly collect or solicit Personal Data from anyone under the Age of Majority (as determined under the applicable laws where the individual resides; “Age of Majority”). By accessing, using or interacting with our Services, you certify to us that you are not under the age of eighteen (18) and not under the Age of Majority at your jurisdiction of residency.
In the event that we learn that we have collected Personal Data from an individual under the Age of Majority without parental or legal guardian consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Age of Majority, then please contact us at: email@example.com.