Privacy Policy

Last Updated on January 01, 2024

We at OTTAGY LLC are committed to protecting your privacy. This Privacy Policy applies to all our Websites (under the main domain and sub-domains of ottagy.com)

This Privacy Policy governs our data collection, processing and usage practices. It also describes your choices regarding use, access and correction of your personal information. If you do not agree with the data practices described in this Privacy Policy, you should not use the Websites or the Subscription Service.

We periodically update this Privacy Policy. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by sending you an email notification.

While we will notify you of any material changes to this Privacy Policy, we encourage you to review this Privacy Policy periodically.

1. Information we collect about you

   Personal and contact information including your name, age, telephone number, postal address, email address, username, social media username(s). We may collect some of that contact information when you interact with us including via our Customer Care Team. Details (and copies) of your communications and interactions with us via our Customer Care Team or otherwise, including by email, telephone (voice recordings), post and online via webchat, the feedback button or on OTTAGY LLC social media channels.

   Copies of documents you provide to prove your identity (including driving license and passport) when there is a legal reason to request this from you.

   Transaction details including payments from you for subscription or purchase of our courses and/or services.

   Your financial information including your payment card information (which is sent to PayPal or Stripe) when you make a purchase or subscribe to a course.

   Information about how you use our app or website, and which websites you came to us from.

   Technical information about your device or browser when you use our app or website, including geolocation data to determine what country you are accessing our website or app from, your internet protocol (IP) address, device ID, browser type and version and time zone setting, which may in some circumstances be personal data.

   We may also receive personal data directly from you or from various third parties and public sources, including from social media channels (if you interact with us through those channels), or other third parties.

2. How and why we use your personal data

   In the table below, we set out all of the ways we use your personal data, and why. We have also identified what our legitimate interests are where appropriate.

   It is sometimes necessary for us to process your personal data in order to enter into a contract with you, or to satisfy a contractual requirement (referred to as ‘performance of a contract with you’ below), or to comply with a statutory requirement. In those circumstances, if you do not provide the personal data we require, we will be unable to provide our courses or other services to you.

   Registration

   We use your personal and contact information to register you as a new student/client.

   We collect financial information if you register payment card information when purchasing or subscribing to one of our courses or services.

   Necessary for the performance of a contract with you.

   Accessing our course content

   We use the personal and contact information provided by you and the transaction details about your purchases, to provide our courses and other services to you.

   Necessary for the performance of a contract with you.

   Managing your account

   We use your personal and contact information, financial information, and transaction details about your purchases, to manage your account.

   Necessary for the performance of a contract with you.

   Communicating with you

   We use the personal and contact information provided by you, copies of your communications with us and, in some circumstances, transaction details, to manage our relationship with you. For example:

   to notify you about changes to our Account Terms or Privacy Policy;

   to communicate with you in response to any query, request or complaint you may have including by email, telephone and in web chat whether relating to any course or subscription that you have purchased from us or otherwise.

   Necessary for the performance of a contract with you.

   Necessary to comply with a legal obligation.

   Necessary for our legitimate interests (to keep our records updated and to study how students use our courses).

   Staff training

   We may use copies of your communications with us (including voice and video meeting recordings) in order to train our staff or relay information for project management purposes.

   Necessary for our legitimate interests (to ensure that we are able to provide the best service to you).

   Market research

   We may use the personal and contact information you have provided to ask you to take part in market research or a survey.

   We also use the results of any surveys or market research that you undertake to improve our app, our website, or our service.

   Necessary for our legitimate interests (to assess and improve our training, courses, service and business).

   Prize draws and competitions

   We may use your personal and contact information, transaction details, and financial information as part of a prize draw or competition.

   Necessary for the performance of a contract with you.

   Technical issues

   If you contact us about an issue, we may use technical information, and personal and contact information to administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

   Necessary for our legitimate interests (for running OTTAGY LLC, the provision of administration and IT services, security and fraud prevention)

   Necessary to comply with a legal obligation.

   Experience

   We use information about your use of our app or website, together with technical information about your device and (in some circumstances) your personal and contact information, and other relevant information that we receive from you or third parties (including aggregated information that we combine with your personal data), to deliver relevant website content, prize draws, competitions and other marketing to you, and to manage the delivery of that content.

   For example, we may automatically display relevant advertisements to you based on your use of our website. Necessary for our legitimate interests (to ensure that you are shown relevant content based on your use of our app or website).

   Advertising effectiveness

   We use information about your use of our app or website and, in some circumstances, personal and contact information about you, to measure or understand the effectiveness of the advertising we serve to you.

   Necessary for our legitimate interests (to determine how effective advertising is in order to improve advertising, its relevance and in order to fulfill contracts we have with our marketing partners).

   Analytics

   We use information about your use of our app or website and technical information, including about your device or where you are accessing our app or website from, to optimize our service and to improve our app, website, services, direct marketing, student relationships, behavior profiling, and experiences.

   Necessary for our legitimate interests (to measure the interactions with our website, to define types of students of OTTAGY LLC, how students use the courses, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

   Winners

   If you win on a OTTAGY LLC competition/draw, we may use your personal and contact information to contact you to arrange support.

   Necessary for our legitimate interests (to develop our courses and to manage our winner services).

   Publicity

   We may use your personal and limited contact information in any publicity materials provided that you have given your consent.

   Regulatory compliance

   We may use your personal and contact information, financial information, information about any transaction between you and us, information about your use of the app or website, or technical information, to enable us to comply with our legal and regulatory obligations.

   Necessary to comply with a legal obligation.

   Fraud prevention

   We may use your personal and contact information, financial information, information about any transaction between you and us, information about your use of the app or website, or technical information, in order to undertake analysis for the purposes of identifying and dealing with any fraud or fraudulent activity.

   Necessary to comply with a legal obligation.

   Necessary for our legitimate interests (to ensure that transactions and interactions with us are not fraudulent).

   Queries

   We may use your personal and contact information, financial information, information about any transaction between you and us, information about your use of the app or website, or technical information for the purpose of dealing with any request, complaint or query from you.

   Necessary to comply with a legal obligation.

   Necessary for our legitimate interests (to respond to you and to deal with any request you may have).

   We use your personal data to create aggregated data sets. You are not identifiable from that aggregated data and it is not considered personal data.

   However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

3. How we use your personal data for marketing

   We send you marketing communications through a number of different channels. You may receive newsletters, email notifications, and other marketing communications that either you request from us or which you consent to by opting in when completing a registration form on our service., and/or have not asked us to stop sending marketing by email to you.

   How to opt out of marketing.

   You may opt out from receiving such marketing communications and notifications from us at any time. There are several ways you can do this. To stop receiving marketing by email, either:

   Click ‘unsubscribe’ or update preferences in any email communication we send;

   Contact us in writing; or

   Email us at nash@ottagy.com

4. How we share your data with third parties

   We sometimes share the data we collect from you with the following trusted third parties:

   How to opt out of marketing.

   You may opt out from receiving such marketing communications and notifications from us at any time.

   There are several ways you can do this. To stop receiving marketing by email, either:

   Banks and payment providers – to set up and/or to obtain payment of any amounts due to us.

   Our IT system providers – in order to provide software to set up your account, to communicate with you via webchat and other communications providers and to provide our systems to us, including for the purposes of hosting, support and software licensing.

   Social media platforms – for the purpose of fulfilling the service and targeted advertising.

   Online survey companies and market research agencies – to undertake surveys (including, for example, our website satisfaction survey) and other market research and to analyze the results.

   Digital analytics companies – for the purposes of website analytics and reporting in respect of our analytics and marketing.

   Professional advisers including lawyers, bankers, auditors and insurers – for the purposes of providing consultancy, banking, legal, insurance and accounting services.

   Police or other such regulatory authority – as part of an investigation or otherwise for legal or regulatory purposes.

   Auditors – to audit our systems and transactions for the purposes of ensuring efficiency, or regulatory or contractual compliance.

   We will disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request. We do this in order to protect our rights, property or safety or of our clients, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

5. How we protect your data

   We have put various measures in place to protect your personal data:

   Our entire site is accessed using https rather than http, meaning that all information that is sent and received is encrypted for additional security. You can see this in the address bar of your browser.

   As described in this Privacy Policy, we may in some instances disclose your personal data to third parties. Where we do, we require that third party to have appropriate technical and organizational measures in place to protect your personal data; however, in some instances, we may be compelled by law to disclose your personal data to a third party, and have limited control over how it is protected by that party.

   Your personal data may be processed outside the European Economic Area (EEA) – including by staff operating outside the EEA who work for us or for one of our third parties mentioned.

   Where your personal data is transferred outside of the EEA, we require that appropriate safeguards are in place.

6. How long we keep your personal data

   We will only keep your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

   At the end of that retention period, your data will either be deleted or anonymized (so that it can no longer be associated with you) for research or statistical purposes.

   To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

   In some circumstances, you may be entitled to ask us to delete your data: see ‘Your rights’ below for further information.

7. Your rights

   You have the right:

   to ask us not to use your personal data for marketing

   to ask us not to process your personal data where it is processed on the basis of legitimate interests if there are no compelling reasons for that processing;

   to request from us access to personal information held about you (see below);

   to ask for the information we hold about you to be rectified if it is inaccurate or incomplete;

   to ask that we stop any consent-based processing of your personal data after you withdraw that consent;

   to ask, in certain circumstances, to delete the personal data we hold about you;

   to ask, in certain circumstances, for the processing of that information to be restricted; and

   to ask, in certain circumstances, for data portability.

8. Contact us

   If you have any questions about our Privacy Policy, including any requests to exercise your rights, please contact the Data Protection Officer using the details set out below:

   By post to:

   Data Protection Officer

   OTTAGY LLC, 447 Broadway, 2nd FL 2380, New York, NY 10013, United States

   By email to: nash@ottagy.com

   In order to request a copy of the personal data that OTTAGY LLC holds about you, please send your request in writing to the Data Protection Officer at the above address. To enable us to verify your identity and process your request, you must include all of the following information and documentation with your request:

   your full name;

   the email address registered to your account;

   a description of the data that you are requesting, including a date range;

   proof of your ID;

   the date of the request.

   If you are unhappy with our processing of your personal data, you have the right to complain at any time. We would, however, appreciate the chance to deal with any concerns before you approach the appropriate authority, so please contact the Data Protection Officer by email in the first instance.

9. Cookies

   We use cookies and similar technologies to recognize you, your browser and your device. We also allow carefully selected third parties to use cookies, pixels and ad tags while you are browsing our website and using our app. These collect information about your browsing habits and usage and allow us to show you ads while you are browsing our website and other sites on the internet. All of our advertising cookies used are described in the cookie list below.

   There are four main types of cookies and technology.

   Here’s how and why we use them:

   Strictly necessary cookies

   These are cookies that are required for the operation of our website and app. Without these cookies, you will not be able to use some functionality on our website and app, such as signing into your account.

   Performance cookies

   These cookies collect information about how you use our website or app and help us improve the way our website and app work by making it easier for you to navigate to and complete various tasks.

   Functionality cookies

   These cookies allow us to identify whether you are logged into your Done-For-You Agency portal and to remember choices you make and your preferences, in order to improve your experience of our website and app.

   Advertising cookies and pixels

   Our carefully selected media partners place third-party cookies, pixels and ad tags onto our website and app on our behalf. These cookies record your visit to our website and/or app, the pages you have visited and the links you have followed.

   We use this information to make our website and app, and the content displayed on them, more relevant to you. They are also used to limit the number of times you see certain content, as well to measure the effectiveness of our digital campaigns.

   We may share this analytics information with third parties for these purposes. You can delete these cookies and still continue to use the website and app.

   More information about these types of cookies and opt-out information can be found in Manage your cookies.

   Managing your cookies

   For more information about cookies, how to opt out and the steps you can take to protect your privacy on the internet, go to http://www.youronlinechoices.com – the guide to online behavioral advertising and privacy. This website is operated by the Internet Advertising Bureau, the industry body for online advertising. On here you’ll find information about how behavioral advertising works, how to opt out, further information about cookies and the steps you can take to protect your privacy on the internet.

   If you’d prefer to restrict, block or delete cookies from our website, you can do so in your browser settings. If you choose to disable cookies, then please note that this may limit the way you use our Website. For example, you may have to re-enter information that would have ordinarily been stored as a cookie.

   Changes to this Privacy Policy

   Any changes that we may make to our Privacy Policy in the future will be posted on our website. Where appropriate, we will notify you of the changes periodically.

   Last Updated on December 26th, 2023