OTC Digital LTD, whose head office is located at Parkside House, 41 Walsingham Road, EN2 6EY Enfield in United Ki_ngdom, registered company under the number 10744879 (hereinafter « OTC Digital », « we » et « our »), in its capacity as controller, attaches great importance to the protection of your personal data and respect for your privacy.
The purpose of this policy is to inform you of our practices regarding the collection, storage, use and sharing of information that you provide to us through our service (the "Service") accessible from our website or from our mobile apps
1. What are your rights regarding your personal data?
Where provided by applicable law, you have the right to obtain a copy of the personal data that we hold about you. Before responding to your request, we may:
(i) check your identity
(ii) ask you to provide us with more information to answer your request
You can also modify or delete this information by contacting us directly via the contact form on the site. Please note that we may retain certain information about you when required by law or when we have a legitimate reason to do so.
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 is likely to identify you ("Personal Data"). This is particularly the case when you fill in forms or contact us. This information contains the following data:
2.1.1. The data necessary for registration on our Service or access to any other service provided by us. This data includes your first and last names, email address, date of birth, gender, phone number, username and password. This information is obligatory. Otherwise, we will not be able to deliver the services we offer 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 communications between you and OTC Digital LTD;
2.1.5. A copy of all publications made on our Service;
2.1.6. Details of the financial, accounting or other transactions performed on our Service;
2.1.7. The details of your visits to our Service and the content you have accessed.
2.2. The data we collect automatically:
2.2.2. During each of your visits, we may collect, in accordance with the applicable legislation and with your agreement where necessary, 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 path on the different URL pages of our Service, the content that you access or view, the search terms used, download errors, the length of time that certain pages are viewed, the advertising ID of your device, interactions with the page and any phone number used to contact us. One of the methods we use to collect this information is cookies.
2.3. Shelf life of your data:
2.3.1. With the exception of the Personal Data categories referred to in Articles 2.3.2. and 2.3.3. below, your Personal Data is archived after 5 years from when you last used our Service, if you have not closed your account;
2.3.2. The following categories of Personal Data may be retained for different durations:
- Financial data (e.g. payments, refunds, etc.) are kept for the time required by applicable tax and accounting laws;
- Content created by you on our Service (such as comments, reviews and ratings) is rendered anonymous after the period mentioned in 2.3.1, but may remain visible on our Service.
2.3.3. In the event that your account has been suspended or blocked, we keep your data for a period ranging from 2 to 10 years from the suspension in order 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 in order to:
3.1. execute the contract between you and us and to provide you with the information and service requested;
3.2. send you information about our Service by email, SMS or any other means (for example, payment confirmations);
3.3. allow you to personalize your profile on our Service;
3.4. enable you to communicate and interact with other members of our community;
3.5. provide you access and allow you to communicate with our customer services in case of any questions or problems;
3.7. send you marketing, advertising and promotional messages, or suggest and make you aware of goods or services that may be of interest to you, in accordance with the applicable legal provisions and with your agreement when the legislation so requires. We may also use your data to send you advertising messages that may be of interest to you on social media platforms or third party sites. If you want more information about this, please read the contractual documents of these platforms;
3.8. inform you of changes to our Service;
3.9. manage our Service and perform internal technical operations for problem solving, data analysis, testing, research, analysis, studies and surveys;
3.10. improve and optimize our Service, in particular to ensure that the display of our content is adapted to your device;
3.11. help us preserve a healthy and secure environment on our Service;
3.12. evaluate the effectiveness of the advertising messages we send you and adapt them to all our members.
4. Why do we collect information about you and to whom do we transmit it?
4.1. As part of the use of our services, some of your information is passed on to 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 LTD Group entities within the scope of this policy.
4.3. We also work closely with third-party companies that can access your Personal Data, including:
- social networking platforms that can offer you features that allow you to integrate information from your account on their platform into your profile on our Service;
- our business partners who promote their services through our Service and to which you may decide to subscribe;
- our business partners on the website with whom we may occasionally advertise our Service;
- the subcontractors we use in terms of technical services, payment services, identity verification or the suppliers of analytical solutions and collection companies and credit institutions;
4.4. We only share your data with the third parties mentioned in 4.3. above in the following cases:
4.4.1. When we engage a service provider in the performance of any contract between you and us or to provide or improve our services (for example in the context of payments made);
4.4.2. As part of the registration process, in order to provide the services requested our Service needs to display or to transmit some of your Personal Data to other members, such as your nickname, photograph, mobile phone number or E-mail address;
4.4.3. When we use search engine providers and analytics solutions to improve and optimize our Service;
4.4.4. When you expressly request it (for example when using authentication methods provided by social networks);
4.4.5. When we post certain parts 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;
4.4.7. In the event that we sell or acquire a business or its assets, 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 by a third party, the data in our possession will, if necessary, be transferred to the new owner;
4.4.9. In accordance with applicable law and with your consent when required, 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 purposes described above.
4.4.10. We draw your attention to the fact that if you decide to let us access some of your information, including your Personal Data, through connection services provided by our business partners, their privacy policies are also enforceable because 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. However, it is possible that the data we collect when you use our Service is transferred to other countries, some of which may have less stringent personal data protection legislation than that in force in the country in which you reside.
This is particularly the case with regard to the data transmitted to our subcontractors located outside the European Union, in particular in the United States. We may use their services to respond to your requests, moderate photographs published on our Service, provide online payment tools, or to receive commercial and advertising services or email and SMS services.
This is also the case for companies affiliated with OTC Digital LTD 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 case of such transfer, we make sure that the processing is carried out in accordance with this policy and that it is framed by the standard contractual clauses of the European Commission which ensure a sufficient level of protection of privacy and the fundamental rights of individuals. On request, we can provide you with the list of countries where we store your data and those to which they are occasionally passed.
5. Targeted advertising and emails that you may receive
In accordance with applicable law and with your consent when required, we may use the data you provide us on our Service for business purposes (for example to (i) send you our newsletters, (ii) send you invitations to events or other communications that may be of interest to you; and (iii) display targeted advertising on social media platforms or third-party sites).
With respect to 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.
With regard to targeted advertising:
- On social media platforms (for example Facebook, Twitter): you can deny this treatment at any time by configuring the parameters relating to the advertising of your account;
- On third party sites: you can contact us via the "Contact" form to withdraw your consent or get help in specific cases where you do not know who to contact or how.
6. Privacy of your password
You are responsible for the confidentiality of the password you have chosen or that we have automatically assigned to you to access your account on our Service. You agree to keep this password secret and not to communicate 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 we are not responsible for the use made by these sites of the information collected when you click on these links. We invite you to read the privacy policies of these sites before sending them your Personal Data.