Privacy Policy

Version 2.0 (13/02/2020)

OTC Digital LTD, a private limited company, with its registered office at Parkside House, 41 Walsingham Road, EN2 6EY Enfield, United Kingdom, registered under number 10744879 (hereinafter referred to as "OTC Digital", " we" and "our"), in its capacity as data controller, attaches great importance to the protection of your personal data and respect for your privacy.

The aim of this policy is to inform you of our practices regarding the collection, storage, use and sharing of information that you provide us with through our service (the "Service") accessible from our website or our mobile apps.

This policy, as well as our General Conditions of Use and any document referred to therein, describes how we handle the personal data we collect and provide to you. We invite you to read this document carefully to know and understand our practices regarding the processing of your personal data that we carry out.


1. What rights do you have to your personal data?

Where provided by applicable law, you have the right to obtain a copy of your personal data that we hold. Before responding to your request, we may:

  • verify your identity
  • ask you to provide us with more information so we can respond to your request

You may also modify or delete this information by contacting us directly via the site’s contact form. Please note that we may retain certain information about you when required by law or when we have a legitimate reason to do so.

For example, this will be the case if we consider that you have committed a fraud or breached our Terms of Use, want to prevent you circumventing the rules applicable to our community or a judicial authority requires us to disclose certain information about you in the framework of civil or criminal proceedings. This is also the case for all accounting data, that is to say all payment transactions carried out on our service and for which we have the obligation to keep a history of transactions, and a billing history accompanied by technical and accounting elements of the payment associated with each invoice.


2. The data we collect

We may collect and process the following data:

2.1. The data you send us directly:

By using our Service, you are required to send us information, some of which may identify you ("Personal Data"). This is particularly true when you fill out forms or contact us. This information contains the following data:

2.1.1. Data necessary to sign up to our Service or access any other service provided by us. This data includes your surname and first name, email address, date of birth, gender, phone number, username and password. This information is mandatory. Otherwise, we will not be able to provide the services offered by our Service and you will not be authorized to create an account on our Service.

2.1.2. A photograph;

2.1.3. A postal address;

2.1.4. A copy of all correspondence between you and OTC Digital;

2.1.5. A copy of all posts on our Service;

2.1.6. Details of the financial or accounting transactions completed on our Service or by any other means, including information relating to your credit card and / or your bank details;

2.1.7. The details of your visits to our Service and the content you have accessed.

2.2. The data we collect automatically:

2.2.1. Where you connect to our services using the social media features available to you, we will have access to some of the data (including your first name, last name, photograph, email address and number of Facebook friends) of your account on said social network pursuant to the general conditions of use of the social media concerned. We may also collect some of your Personal Data when you interact with features such as the "Like" feature.

2.2.2. Upon each of your visits, we may collect, pursuant to applicable law and with your agreement, as applicable, information about the devices on which you use our services or the networks from which you access our services, such as your IP addresses, connection data, types and versions of Internet browsers used, types and versions of your browser plugins, operating systems, data about your browsing path on our Service, including your pathways on the various URL pages of our Service, the content you access or view, the search terms used, download errors, the time you spent viewing certain pages, the advertising ID of your device, interactions with the page and any phone number used to contact us. Among the technologies used to collect this information are cookies.

2.3. Data retention period:

2.3.1. With the exception of the categories of Personal Data referred to in Articles 2.3.2. and 2.3.3. below, your Personal Data is archived 5 years after your last use of our Service, if you have not closed your account;

2.3.2. The following categories of Personal Data may be retained for different periods:

  • Financial data (for example payments, refunds, etc.) are retained for the time required by applicable tax and accounting laws;
  • The content created by you on our Service (such as comments, opinions and ratings) is made anonymous after the time frames mentioned in 2.3.1 but may remain visible on our Service.

2.3.3. Where your account has been suspended or blocked, we retain your data for a period ranging from 2 to 10 years after the suspension to avoid any circumvention by you of the rules in effect on our Service.


3. How can we use your data?

We use the data we collect to:

3.1. perform the contract concluded between you and us and provide you with the information and service requested;

3.2. send you information about our Service (such as, for example, payment confirmations) by email, text messages or any other means;

3.3. allow you to personalize your profile on our Service;

3.4. allow you to communicate and interact with other members of our community;

3.5. if you have any questions or problems, give you access to, and allow you to communicate with, our customer service;

3.6. ensure compliance with (i) the applicable law, (ii) our general conditions of use, (iii) our privacy policy and (iv) our charter of good conduct;

3.7. send you, pursuant to applicable law, and with your agreement when the law so requires, marketing, advertising and promotional messages, or suggest and recommend goods or services that may be of interest to you. We may also use your data to send you advertising that may be of interest to you on social media platforms or third-party sites. If you would like further information on this subject, we invite you to read the contractual documents of these platforms;

3.8. inform you of changes to our Service;

3.9. manage our Service and carry out internal technical operations for problem solving, data analysis, testing, research, analysis, studies and surveys;

3.10. improve and optimize our Service, particularly to ensure that the display of our content is suitable for your device;

3.11. help us preserve a healthy and secure environment for our Service;

3.12. evaluate the efficacy of the advertising messages we send you and adapt them to all our members.


4. To whom, and why, do we collect and transmit your information?

4.1. In the use of our services, some of your information may be shared with other members of our community, through your public profile or as part of the dating process.

4.2. We may also share information about you, including Personal Data, with other OTC Digital entities under this policy.

4.3. We also work closely with third-party companies that may access your Personal Data, including:

  • social media platforms that can offer you features allowing you to include information from your account on their own platform in your profile on our Service;
  • our commercial partners who promote their services on our Service and which you may decide to subscribe to;
  • our commercial partners on the website on which we may advertise our Service;
  • any subcontractors we use in terms of technical services, payment services, identity verification or providers of analytical solutions, as well as collection companies and credit institutions;

4.4. We share your data with third parties mentioned in 4.3. above only in the following cases:

4.4.1. When we contract a service provider as part of the performance of any contract between you and us or to provide or improve our services (for example within the framework of the payments made);

4.4.2. As part of the registration process, we are required, to provide the services requested, to display on our Service or to pass on to another member, some of your Personal Data such as your nickname, photograph, mobile phone number or e-mail;

4.4.3. When we use search engine and analytic solutions providers to improve and optimize our Service;

4.4.4. when you expressly so request (for example when using authentication methods provided by social networks);

4.4.5. When we post certain elements of our Service on the websites of our business partners via APIs or widgets. In this case, some information from your public profile may also be posted on these sites;

4.4.6. Where we have a legal obligation to do so or if we believe in good faith that this is necessary to (i) respond to any claim against OTC Digital, (ii) comply with any court order, (iii) enforce any contract concluded with our members, such as the General Conditions of Use and this Privacy Policy (iv) in the event of an emergency involving public health or a person’s physical integrity, (v) in investigations and surveys, or (vi) to guarantee the rights, property and safety of OTC Digital, its members and more generally any third party;

4.4.7. Where we sell or acquire a business or assets, in which case we reserve the right to share your Personal Data with the potential seller or buyer of this company or these assets;

4.4.8. If OTC Digital or all or part of its assets are bought out by a third party, the data in our hands will, as applicable, be transferred to the new owner;

4.4.9. Pursuant to applicable law and with your consent when necessary, we may aggregate data about you that we receive or send to our business partners, including all or part of your Personal Data and information collected through cookies. This aggregated information will only be used for the ends described above.

4.4.10. We would like to draw your attention to the fact that if you decide to provide us access to some of your information, including your Personal Data, through connection services provided by our business partners, their privacy policies are also enforceable against you, as we have no control over the collection or processing of your data by our business partners on their own platform.

4.4.11. We keep your Personal Data in the European Union. It is nevertheless possible that the data we collect when you use our Service may be transferred to other countries, some of which may have less stringent personal data protection legislation than that in force in your country of residence.

This is particularly true regarding data transmitted to our subcontractors located outside the European Union, particularly in the United States. We may use them to respond to your requests, moderate photographs published on our Service, provide online payment tools or provide us with commercial and advertising services or email and SMS services.

This is also the case for companies affiliated with OTC Digital located outside the European Union, to which we can transfer some of your data as part of the provision of our services in these countries. In the event of such a transfer, we ensure that processing is carried out in accordance with this policy and that it is governed by the standard contractual clauses of the European Commission that ensure a sufficient level of protection of the privacy and fundamental rights of individuals. Upon request, we can provide you with the list of countries where we store your data and those it may occasionally pass through.


5. Targeted advertising, emails that you may receive

Pursuant to applicable law and with your consent when required, we may use the data you provide us with on our Service for commercial canvassing purposes (for example, to (i) send you our newsletters, (ii) send you invitations to our events or other communications that may be of interest to you; and (iii) display targeted advertising on social media platforms or third-party sites).

In terms of promotional emails, you may withdraw your consent at any time by (i) unchecking the box in your account, (ii) clicking on the unsubscribe link provided in each of our communications or (iii) contacting us directly.

Regarding targeted advertising:

  • On social media platforms (for example Facebook, Twitter): you can object to this processing at any time by configuring the parameters relating to advertising in your account;
  • On third-party sites: You may contact us via the "Contact" form to withdraw your consent or seek help in specific cases where you do not know who to contact or how.

6. Confidential nature of your password

You are responsible for the confidentiality of the password you have chosen or that we have automatically assigned you to access your account on our Service. You agree to keep this password secret and not to disclose it to anyone.


7. Links to third party sites

Our Service may occasionally contain links to the websites of our partners or third parties. Please note that these websites have their own privacy policies and that we are not responsible for the use by these sites of the information collected when you click on these links. We recommend you read the privacy policies of these sites before sending them your Personal Data.


8. Modification of our privacy policy

We may occasionally be required to modify this Privacy Policy. When necessary, we will notify you of this and/or seek your agreement. We recommend you regularly check this page to find out about any changes or updates to our privacy policy.