Privacy Policy

Introduction

Any data collected through the otmcreate.com website including Personal Data, will only be used when you register, request information or a response from OTM to better target you for further sales and marketing opportunities. Once collected, Personal Data will not be used for a different incompatible purpose without your consent.

We take the protection of data privacy very seriously. All Personal Data collected through the website application will be treated as strictly confidential and will only be used as set out in this Privacy Notice. The applicable data protection laws shall be respected in full.

Therefore, please read this Privacy Notice thoroughly. If you disagree with the way Personal Data will be used, please do not use this Website or provide your Personal Data through the Website.

Specifically, OTM is committed to ensuring that all data processing is:

• processed lawfully, fairly and in a transparent manner;
• collected for specified, explicit and legitimate purposes;
• adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
• accurate and, where necessary, kept up to date;
• kept in a form which permits identification of data subjects for no longer than is necessary; and
• processed in a manner that ensures appropriate security of the personal data.

We are committed to safeguarding the privacy of anyone who shares personal data with OTM; this policy sets out how we will treat your personal information.

1. OTM as Data Controller and Data Processor

1. OTM acts as Data Controller for information which is acquired and processed for internal use.
2. OTM acts as Data Processor for the services and products it develops on behalf of its clients where this involves the processing of personal data. This data is processed in accordance with OTM’s Data Protection Policy and the GDPR and only as instructed by the client.

This Privacy Policy deals with information collected and processed as Data Controller.


2. What information do we collect?

We may collect, store and use the following kinds of personal information:

1. Information relating to our business relationship and any transactions carried out between you and us.
2. Your Personal Information:
We collect the following Personal Data from you: your first and last name, company, title, work email, phone number, country and your reason for contacting us.

3. Browser Information

Information about your computer and about your visits to and use of the website e.g. IP address, geographical location, browser type and version, operating system type and version, referral source, length of visit, page views, website navigation paths and service usage).

1. Information that you send to us in order to apply for a job advertising on the site.
2. Information that you provide to us when subscribing to newsletter, white paper or blog post.
3. Any other information that you choose to send to us

4. What legal ground(s) do we rely on?

Where Personal Data is provided by you through the Website, we will obtain your explicit consent. Please note that you can withdraw or revoke your consent to our use of your Personal Data at any time. You always have a choice concerning whether or not you provide Personal Data.

The use of the Personal Data is further necessary for the purposes of OTM legitimate interest

1. in improving our services, so we can better understand your needs and expectations and therefore improve our services to you;
2. to prevent fraud and to ensure that the use of our web services is complete and without fraudulent behaviour;
3. to ensure the security of our services and to ensure that our offerings are technically secure and functioning properly.


5. Using your personal information

Personal information submitted to us in the course of our interactions will be used for the purposes specified in this privacy policy. The legal basis on which OTM processes personally identifiable data is ‘legitimate interests’ as set out in the GDPR.

We will share your Personal Data with employees of OTM, including Sales, Marketing, IT and Operations Teams in order to create inter alia email campaigns and other marketing efforts.

We will not disclose your Personal Data to anyone else under any circumstances except as otherwise stated in this Privacy Notice, to successors in title to our business, to establish, exercise or defend our rights, or where required by law.

We may use your personal information to:

1. Keep records of our business relationship.
2. Send statements and invoices to you and collect payments from you.
3. Send you general (non-marketing) commercial communications.
4. Send to you marketing communications relating to our business by email or similar technology (you can inform us at any time if you no longer require marketing communications).
5. Deal with enquiries and complaints made by or about you.

Where we use external services to process your personal data this is done only to the extent where it is necessary to provide the service.

6. Other disclosures

We may disclose information about you to OTM employees, agents, suppliers or third parties insofar as reasonably necessary for the purposes as set out in this privacy policy. Our list of third-party data processors includes but is not limited to Hubspot (CRM), Microsoft (Office 365 including email), Mailchimp (email distribution), Google (Analytics), Citation Processional HR Services and Abacus Pay Roll (Finance and HR), and Stripe disaster recovery servers (backup). Further detailed information is available on request.

If the services of third parties for the technical maintenance, administration or processing of data are required, the Personal Data will be accessed by these parties only to the extent that is required to ensure a smooth and secure technical handling of the Website and in compliance with applicable law, including with respect to data confidentiality, privacy and security.

In addition, we may disclose your personal information:

1. To the extent that we are required to do so by law.
2. In connection with any legal proceedings or prospective legal proceedings.
3. In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

7. International data transfers

Information which you provide is only transferred to countries which have data protection laws equivalent to those in force in the European Economic Area and only for the purposes stated in this policy.

8. Cookies or other tracking technology

A cookie is a small file which is placed on your computer's hard drive. If you choose to accept cookies, the file is added, and the cookie helps to analyse web traffic or lets us know when you visit a particular site. Cookies further allow us to respond to you as an individual and we can tailor our operations to your needs, likes and dislikes by gathering and remembering information about your preferences when you return to our site and for logged-in users to maintain the session and remember table filters. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Website.

9. Security of your personal information

We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. We use a variety of methods, such as firewalls, intrusion detection software and manual security procedures, to secure your data against loss or damage and to help protect the accuracy and security of Personal Data and to prevent unauthorised access or improper use. If you think that the Website or any Personal Data is not secure or that there has been unauthorised access to the Website or your Personal Data, please contact info@otmcreate.com immediately.

10. Notification of private policy changes

We may update this privacy policy from time-to-time by posting a new version on our website. You should check this page occasionally to ensure you are happy with any changes.

Continued use of the Website after a change in the Privacy Notice indicates your acknowledgement and acceptance of the use of Personal Data in accordance with the amended Privacy Notice.

We may from time to time also notify you of changes to our privacy policy by email.

11. Your rights

You may instruct us to provide you with any personal information we hold about you. Provision of such information will be subject to the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

We may withhold such personal information to the extent permitted by law.

You may instruct us not to process your personal information for marketing purposes by sending an email to us. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt-out of the use of your personal information for marketing purposes.

12. Updating information

Please let us know if the personal information which we hold about you needs to be corrected or updated.

13. How to contact OTM

If you have any questions or consider that we are not complying with this privacy policy or information we hold about you, please contact us:
• by email to info@otmcreate.com
• or write to Privacy Officer OTM 45-51 Whitfield Street, London, W1T 4HD