Last modified: 10/31/2021
This document describes the policies and practices of OTTera, Inc. (“Company” or “We”) as related to information (as defined herein). This policy describes the types of information we may collect and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
- On our website or through our products and services.
- In email, text, and other electronic messages between individuals and us.
- From third parties (“Partners”).
- During the provision of our services on behalf of our Partners.
It does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries);
Children Under the Age of 13
Children can access many parts of our products and services and their content and use many of its features without providing us with personal information. However, some content and features are available only to registered users or require us to collect certain information, including personal information, from them. In addition, we use certain technologies, (as otherwise stated in this policy), to automatically collect information from our users (including children) when they visit or use our products and services.
For services intended for children, we obtain verifiable parental consent related to those users (either directly or as indicated by our Partners directing those child users). Adults are not allowed to access any children-directed services. At sign-up, a child (or parent, on behalf of a child) must provide us with the following information to register with our products or services: a selected randomly generated username for the child and a parent’s email address. We may request additional information from children, but this information is optional. We specify whether information is required or optional when we request it. We may also combine non-personal information we collect through these technologies with personal information about parents or children that we collect online (see How We Use Information and Information We Collect Through Automatic Data Collection Technologies).
We only collect as much information about a child as is reasonably necessary for the child to participate in an activity, and we do not condition his or her participation on the disclosure of more personal information than is reasonably necessary. We support do not track and personal information obfuscation in compliance with COPPA, and do not knowingly store anything traceable or identifiable are stored on COPPA required clients.
At any time, parents or children may review a child’s personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using the child’s information.
Parents and children can review, change, or delete a child’s personal information by:
- Logging into that child’s account and visiting his or her account profile page.
- Sending us an email at firstname.lastname@example.org. To protect privacy and security, we may require a requester to take certain steps or provide additional information to verify identity before we provide any information or make corrections.
A list of all operators that may collect or maintain personal information from children through our products or services will be provided upon written to email@example.com. Please direct inquiries about any operator’s privacy practices and use of children’s information to the operator at its contact information provided on their website.
To the extent that certain products or services are not directed to children, we obtain confirmation from the user that they are not a child. We do not knowingly collect or obtain information from children related to these products and services or through any other means besides our products or services not directed to children. If we learn we have collected or received personal information from a child without verification of parental consent related to these products and services, we will delete that information. If you believe we might have any information from or about a child in relation to these services, please email us at firstname.lastname@example.org.
Information We Collect and How We Collect It
We collect several types of information from and about users, including information:
- By which an individual may be personally identified, such as name, e-mail address, billing address, or telephone number, or information that alone cannot personally identify a user but may be used to personally identify a user in combination with other information (such as gender, age, location, IP address, device identifiers, or usage behavioral information) (“personal information”);
- That is about a user but individually does not identify that user, such as aggregated information or anonymized information; and/or
- About users’ internet connection, the equipment users use to access our products and services, and usage details.
- We collect this information:
- Directly from users when they provide it to us.
- Automatically as users navigate through our products and services. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
- From third parties, for example, our Partners.
Information Users Provide to Us
The information we collect on or through our services may include:
- Information that is provided by filling forms on our products or services. This includes information provided at the time of registering for use.
- Records and copies of correspondence (including email addresses) if a user contacts us.
- Details of transactions carried out through our products and services. Users may be required to provide financial information before placing an order through our products or services, which is submitted directly to our payment processing Partners. We do not collect financial information (whether directly from you or from our payment processing Partners) except in truncated or aggregated form that cannot be used to uniquely identify you or to fraudulently act as you in a financial setting. Your financial information that you submit through our products or services may be subject to the privacy policies of those payment processing Partners.
- Information inferred or derived from the use of our products or services (including information derived from search queries, viewing behaviors, and usage details).
Information We Collect Through Automatic Data Collection Technologies
As users navigate through and interact with our products and services, we may use automatic data collection technologies to collect certain information about users’ equipment, browsing actions, and patterns, including:
- Details of use or visits to our products and services, including traffic data, location data, logs, and other communication data and the resources utilized for such use or visits.
- Information about users’ computer and internet connection, including users’ IP address, operating system, and device ID.
- Information about users’ use of our products or services.
The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our products and to deliver a better and more personalized services, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about user preferences, allowing us to customize our products or services according to users’ individual interests.
- Speed up searches.
- Recognize users when they return to our products or services.
- Provide content that may be of interest to our users.
The technologies we use for this automatic data collection may include:
- Web Beacons. Some of our products or services may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related statistics (for example, recording the popularity of certain content and features or verifying system and server integrity).
We do not control those Partners’ tracking technologies or how they may be used. Any questions about an advertisement or other targeted content should be directed to the responsible provider.
How We Use Information
We use information that we collect about users or that users provide to us, including any personal information:
- To present our products and services, and their contents.
- To provide information, products, or services requested from us.
- To fulfill any other purpose for which the information is provided.
- To carry out our obligations and enforce our rights arising from any contracts entered into by us, including for billing and collection.
- To notify users about changes to our products or services we offer or provide though it.
- To allow users to participate in interactive features on our products or services.
- To optimize our business operations or the user experience of our products or services.
- In any other way we may describe the information is provided.
- For any other purpose with appropriate consent.
We may use the information we have collected to enable us to display advertisements to our advertisers’ target audiences. Even though we do not directly collect or disclose personal information for these purposes inconsistently with your device’s settings (see Information We Collect Through Automatic Data Collection Technologies above), if users click on or otherwise interact with an advertisement, the advertiser may assume that such users meet its target criteria.
Disclosure of Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
- To our subsidiaries and affiliates.
- To contractors, service providers, and certain other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of OTTera, Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by OTTera, Inc. about our users is among the assets transferred.
- With our Partners only to the extent that they have represented they have obtained consent from relevant data subjects or otherwise have a valid, reasonable basis for obtaining, collecting, processing, or using such information.
- To fulfill the purpose for which it is provided.
- For any other purpose disclosed by us when provided with the information.
- With a data subject’s consent.
We may also disclose personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of OTTera, Inc., our customers, our users, our data subjects or others.
Choices About How We Use and Disclose Information
We strive to provide users with choices regarding the personal information they provide to us. We have created mechanisms to provide users with the following control over their information:
- Tracking Technologies and Advertising. Users can set browsers or devices to refuse all or some browser cookies, or to alert when cookies are being sent. If cookies are disabled or refused, note some parts our products or services may then be inaccessible or not function properly.
- Account Settings. Users can adjust how some of their information (including personal information) is disclosed through their account settings.
We do not control third parties’ (including Partner’s) collection or use of information to serve interest-based advertising. However, these third parties may provide ways to choose not to have information collected or used in this way.
Regional- or Jurisdictional-Specific Disclosures
We may sell or disclose to a third party personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Californians have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. Effective January 1, 2023, Californians have the right under the California Privacy Rights Act of 2020 (CPRA) to limit the use of certain categories of personal information that are considered sensitive, including (but not limited to) race, religion, union membership, or sexual orientation (collectively, “sensitive personal information”) to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services, to perform the services set forth in paragraphs (2), (4), (5), and (8) of subdivision (e) of California Civil Code Section §1798.140, and as authorized by regulations adopted pursuant to subparagraph (C) of paragraph (19) of subdivision (a) of California Civil Code Section §1798.185.
California’s “Shine the Light” law (California Civil Code Section § 1798.83) permits users of our products and services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com.
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated email address: firstname.lastname@example.org. However, please know we do not currently sell data triggering that statute’s opt-out requirements.
Accessing, Correcting, Deleting, and Controlling the Use of Information
Individuals may send us an email at email@example.com to request access to, correct, opt-out of the sale or disclosure, or delete any personal information provided to us, or to limit our use of your sensitive personal information. We will respond to such requests in a timely fashion, though may require additional verification steps (as required by law) before granting any requests. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Please note that deleting your account through your account settings may not fully delete all of your personal information associated with it. If you wish to confirm deletion of the entirety of personal information associated with your account, please follow the mechanism described in the previous paragraph.
Residents of certain countries or states may have additional personal information rights and choices. Please see Regional- or Jurisdictional-Specific Disclosures for more information.
We have implemented measures designed to secure personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information provided to us is stored on our secure servers behind firewalls, and personal information is stored in encrypted or hashed form. Any payment transactions will be encrypted using SSL technology.
The safety and security of information also depends on our users. Where we have given users (or where it is otherwise supplied) a password for access to certain parts of our products and services, users are responsible for keeping this password confidential. We ask not to share passwords with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect personal information, we cannot guarantee the security of personal information transmitted to our us or our other products or services. Any transmission of personal information is users’ own risk. We are not responsible for circumvention of any privacy settings or security measures that we have implemented in our products or services.