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OTPPAY OU Privacy Policy

Last updated : 13-08-2018

Privacy is of utmost importance at the OTPPAY group of companies (“OTPPAY”). We recognize the significance of protecting information which is stored on our computers or is intended to be stored on our computers and which relates to an individual. The data we protect are the “Personal Data” which is any information relating to an identified or identifiable natural person, sometimes called a data subject, and have made protecting privacy and the confidentiality of Personal Data a fundamental component of the way we do business. This Privacy Policy informs you of the ways we work to ensure privacy and the confidentiality of Personal Data. This policy describes the information we gather, how we use those Personal Data and the circumstances under which we disclose such information to third parties.

In this Policy “Services” means the OTPPAY website, any feature provided by us via the website or any local application (mobile desktop or otherwise), including without limitation wallet services or blockchain information services, but excluding API services, which are governed by a separate agreement.

If you do not agree with this Privacy Policy in general or any part of it, you should not use the Services.

Contents

  • Collecting of Personal Information
  • Use of Personal Data
  • Disclosure of Personal Data
  • Security of Your Personal Data
  • Retention of Your Personal Data
  • Storage of Personal Data
  • Your Rights
  • Acceptance
  • Questions and Complaints

1. Collecting of Personal Information

When you access or use the Services, we collect the following information:

Information you may provide to us: You may give us information about you by filling in forms on our website or through our app or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use the Services and when you report a problem with the website or with our app. The information you give us may include your name, email address, virtual currency addresses, business card or other identifying document, mobile phone number, alias, password, mobile PIN code, and any other information you choose to provide.

Information we collect about you: With regard to each of your visits to our website or our app we automatically collect the following information:

  • Log Information: We log technical information about your use of the Services, including the type of browser and version you use, last access time of your wallet, the Internet Protocol (IP) address used to create the wallet and the most recent IP address used to access the wallet.
  • Device Information: We collect information about the mobile device you use to access our mobile application, including the hardware model, operating system and version, unique device identifiers and mobile network information, but this information is anonymized and not tied to any particular person.
  • Address Information: When you create a wallet through our Services, you may choose to generate a public and private key pair. It will be handled by highly secured encryption format.

Information We Collect from Other Sources: We also receive information from other sources and combine that with information we collect through our Services. For instance:

  • When you log in to our support desk center via a third-party social media service, we collect information about your social media account in accordance with the authorization procedures determined by such social media service, including your public profile, friend list and email address.
  • We use third-party services, but will do so with clear notices. Any third-party services may collect information as determined by their own privacy policies.

We also use "cookies" from time to time to help personalize your online experience with us. A cookie is a small text file that is stored on your computer to help us make your visit to our site more “user-friendly.” Please see our Cookies Policy for more details about the cookies we use. Cookies provide us with information about your use of the site that can help us improve the site and your experience with it. We will process Personal Data collected through cookies in accordance with this Privacy Policy. If you have set your browser to warn you before accepting cookies, you should receive a warning message with each cookie. You may refuse cookies by turning them off in your browser, however, you should be aware that our site, like most other popular sites, may not work well with cookies disabled.

2. Use of Personal Data

As it is in our legitimate interests to be responsive to you and to ensure the proper functioning of our products and organisation, we will use your information to:

  • Understand and meet your needs and preferences in using our Services;
  • Develop new and enhance existing service and product offerings;
  • Manage and develop our business and operations;
  • Carry out any purposes for which we have received your consent; and
  • Meet legal and regulatory requirements.

We also reserve the right to use aggregated Personal Data to understand how our users use our Services, provided that those data cannot identify any individual.

We use Google Analytics which is a web analytics tool that helps us understand how users engage with the website. Like many services, Google Analytics uses first-party cookies to track user interactions as in our case, where they are used to collect information about how users use our website. This information is used to compile reports and to help us improve our website. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all website you use.

We will process your Personal Data legally and fairly and not use it outside the purposes of which we have informed you. So far as we are able we shall ensure that all of your Personal Data is accurate and up to date.

3. Disclosure of Personal Data

We share your information with selected recipients to perform functions on our behalf. All such third parties will be contractually bound to protect data in compliance with our Policy. The categories of recipients include:

  • Companies within the OTPPAY OU located in the Estonia and Development Center in India, in order to provide the Services to you.
  • Email providers, like Google G-suit, located in the United States, to provide email services.
  • Cloud services providers, like Google, located in United States, and Amazon, located in Frankfurt, to store certain personal data and for disaster recovery services, as well as for the performance of any contract we enter into with you.

We also may share personal information with 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 OTPPAY’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Data held by OTPPAY is among the assets transferred.

Except where we are required by law to disclose Personal Data or are exempted from, released from or not subject to any legal requirement concerning the disclosure of Personal Data, we will require any person to whom we provide your Personal Data to agree to comply with our Privacy Policy in force at that time or requirements substantially similar to such policy. We will make reasonable commercial efforts to ensure that they comply with such policy or requirements, however, where not expressly prohibited by law, we will have no liability to you if any person fails to do so.

We shall require any third party, including without limitation any government or enforcement entity, seeking access to data we hold to have obtained a Court Order, or proof they are statutorily empowered to access your data and that their request is valid and within their power.

4. Security of Your Personal Data

We protect Personal Data with appropriate physical, technological and organizational safeguards and security measures. Your Personal Data comes to us via the internet which chooses its own routes and means whereby information is conveyed from location to location. As such we cannot give any warranty or assurance that the means where information is conveyed to us are safe, reliable or have integrity. We audit our procedures and security measures regularly to ensure they are being properly administered and remain effective and appropriate. Every member of OTPPAY is committed to our privacy policies and procedures to safeguard Personal Data. Our site has security measures in place to protect against the loss, misuse and unauthorized alteration of the information under our control. More specifically, our server uses SSL (Secure Sockets Layer) security protection by encrypting your Personal Data to prevent individuals from reading these Data as they travel over the Internet.

5. Retention of Your Personal Data

The length of time we retain Personal Data outside our back up system varies depending on the purpose for which it was collected and used, as follows:

  • Data you provide to us when subscribing for our services: while user remains active, stored in the Frankfurt, Germany.
  • Country Location data: while user remains active, stored in the Frankfurt, Germany.
  • Data on your preferences: while user remains active, stored in the Frankfurt, Germany.
  • IP address login: until subsequent login from a new IP, stored in the Frankfurt, Germany.
  • Push notification tokens: 12 months or until deactivation or expiry, stored in the Frankfurt, Germany.

Except where prohibited by law, this period may extend beyond the end of the particular relationship with us but only for so long as we are contractually bound to do so, or so far as is necessary for audit or other accounting purposes. When Personal Data are no longer needed we have procedures either to destroy, delete, erase or convert it to an anonymous form.

After you have terminated your use of our Services, we reserve the right to maintain your Personal Data as part of our standard back up procedures in an aggregated format.

6. Storage of Personal Data

If you reside in the EU, OTPPAY stores your Personal Data at secure locations in the EU. OTPPAY has ensured that appropriate security standards are in place regarding the safeguarding, confidentiality and security of Data.

The information that we collect from you will be transferred to, and stored in, destinations outside of your country and the European Economic Area ("EEA") as described below:

Adequacy Decision: The personal data that we collect from you will be transferred to, and stored at/processed in, the Frankfurt, Germany via encrypted communications channels and stored on hardware owned by OTPPAY for the purpose of operation of Services and disaster recovery, which were found to have an adequate level of protection for personal data under Commission Decision 2000/518/EC of 26 July 2000.

Model Clauses: The personal data that we collect from you will be transferred to, and stored at/processed in the Frankfurt, Germany via encrypted communications channels and stored on hardware owned by OTPPAY for the purpose of operation of Services and disaster recovery, under the Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2010/87/EU.

7. Your Rights

If you are a user of the Services located in the EU, in certain circumstances, you have the right to access and receive a copy of information we hold about you, to rectify any personal data held about you that is inaccurate and to request the deletion of personal data held about you. Any access request after the first such request by you may be subject to a reasonable fee to meet our costs in providing you with details of the information we hold about you. You also have the right to data portability for information you provide to us – this means that you can obtain a copy of your data in a commonly used electronic format so that you can manage and move it. You may have the right to restrict or object to the processing of your personal data by us. You can exercise your rights by contacting us at [email protected]

8. Acceptance

By using the Services, you signify your agreement to this Policy. OTPPAY reserves the right to change this Policy at any time. If we make any material changes to this Policy the revised Policy will be posted here and notified to our users at least 30 days prior to the changes taking effect, so that you are always aware of what information we collect, how we use it and under what circumstances we disclose it. Please check this page frequently to see any updates or changes to this Policy.

9. Questions and Complaints

Any questions about this policy, the collection, use and disclosure of Personal Data by OTPPAY or access to your Personal Data which is required by law (or would be so subject had the storage in question taken place in a relevant EU member state if the case may be but not otherwise) to be disclosed should be directed to [email protected]

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at [email protected] and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection supervisory authority in the country in which you live or work where you think we have infringed data protection laws.

OTPPAY Cookies Policy

Last Updated : 13-08-2018

The OTPPAY group of companies ("OTPPAY") use cookies, pixel tags, web beacons, mobile device IDs and similar files or technologies to collect and store the information we automatically collect about your computer, device, and use of the websites operated by OTPPAY ("Websites"). You can find out more about cookies and how to control them in the information below.

If you do not accept the use of these cookies, please disable them using the instructions in this cookie policy, by following the 'opt-out' links provided below or by changing your browser settings so that cookies from the Websites cannot be placed on your computer or mobile device.

1. What is a cookie?

Cookies are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a certain webpage. Cookies are then sent back to the originating webpage on each subsequent visit, or to another webpage that recognises that cookie. Cookies are widely used in order to make the Websites work, or to work more efficiently, as well as to provide information to the owners of the Website.

Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. Cookies may tell us, for example, whether you have visited the Websites before or whether you are a new visitor. They can also help to ensure that adverts you see online are more relevant to you and your interests.

There are two broad categories of cookies:

  • First party cookies, served directly by us to your computer or mobile device.
  • Third party cookies, which are served by a third party on our behalf. We use third party cookies for [functionality, performance / analytics, advertising and social media purposes].

Cookies can remain on your computer or mobile device for different periods of time. Some cookies are 'session cookies', meaning that they exist only while your browser is open. These are deleted automatically once you close your browser. Other cookies are 'permanent cookies', meaning that they survive after your browser is closed. They can be used by the Websites to recognise your computer when you open your browser and browse the Internet again.

2. How do we use cookies?

We use cookies to:

  • track traffic flow and patterns of travel in connection with the Websites;
  • understand the total number of visitors to our Website on an ongoing basis and the types of internet browsers (e.g. Firefox, Chrome or Internet Explorer) and operating systems (e.g. Windows or Mac OS) used by our visitors;
  • monitor the performance of the Websites and to continually improve them;
  • customise and enhance your online experience; and
  • enable OTPPAY and third-party to advertise both on and off the Websites.

3. What types of cookies do we use?

The types of cookies used by us and our partners in connection with the Websites can be classified into one of five categories, namely 'essential Websites cookies', 'functionality cookies', 'analytics and performance cookies', 'advertising cookies', and ' social media cookies'. We've set out some further information about each category, and the purposes of the cookies we and third parties set in the following table.

Type of cookie What it does How to block
Cookies necessary for essential Websites purposes These cookies are essential to provide you with the Websites and any services available through the Websites and to use some of their features, such as access to secure areas. Without these cookies, services you have asked for, like transactional pages and secure login accounts, would not be possible. Please see the instructions set out in 'How to control or delete cookies' below.
Functionality Cookies Functionality cookies record information about choices you've made and allow us to tailor the Websites to you. These cookies mean that when you continue to use or come back to the Websites, we can provide you with our services as you have asked for them to be provided. For example, these cookies allow us to:
  • Save your location preference if you have set your location on your homepage, if applicable, in order to receive a local weather forecast;
  • Remember settings you have applied, such as layout, text size, preferences, and colors;
  • Show you when you are logged in; and
  • Store accessibility options.
Please see the instructions set out in 'How to control or delete cookies' below.
Performance / Analytics Cookies We use performance/analytics cookies to analyze how the Websites are accessed, used, or is performing in order to provide you with a better user experience and to maintain, operate and continually improve the Websites. For example, these cookies allow us to:
  • Better understand our Websites visitors so that we can improve how we present our content;
  • Test different design ideas for particular pages, such as our homepage;
  • Collect information about Websites visitors such as where they are located and what browsers they are using;
  • Determine the number of unique users of the Websites;
  • Improve the Websites by measuring any errors that occur; and
  • Conduct research and diagnostics to improve product offerings.
Please also see the instructions set out in 'How to control or delete cookies' below.
Advertising and Tracking Cookies As you use our Websites, you will notice that they feature advertising. We allow third party companies, including advertising companies, to place cookies on our Websites. These cookies enable such companies to track your activity across various sites where they display ads and record your activities so they can show ads that they consider relevant to you as you browse the Internet. These cookies are anonymous -- they store information about the content you are browsing, but not about who you are.
Cookies also allow us and third parties to know whether you've seen an ad or a type of ad, and how long it has been since you've last seen it. This information is used for frequency capping purposes, to help tailor the ads you see, and to measure the effectiveness of ads.
All the ad companies or networks that we work with have their own privacy policies and offer a mechanism for users to opt out tracking and behavioral targeting available through the ad itself or through the opt out mechanisms listed in the 'How to control or delete cookies' section below.
Social Media Cookies On some pages of our Websites, third parties that provide applications through our Websites may set their own anonymous cookies in order to track the success of their applications or customize applications for you. For example, when you share an article using a social media sharing button on our Websites (e.g., Facebook, Twitter, or Google Plus), the social network that has created the button will record that you have done this. Because of how cookies work, we cannot access these cookies, nor can the third parties access the data in cookies used by us. Some pages of our Websites may also contain embedded content, such as video content from YouTube, and these sites may set their own cookies. Please see the instructions set out in 'How to control or delete cookies' below.

4. How to control or delete cookies

You have the right to choose whether or not to accept cookies and we have explained how you can exercise this right below. However, please note that if you choose to refuse cookies you may not be able to use the full functionality of our Websites.

Most browsers allow you to change your cookie settings. These settings will typically be found in the “options” or “preferences” menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the “Help” option in your browser for more details.

  • Cookie settings in Internet Explorer
  • Cookie settings in FirefoxCookie settings in Firefox
  • Cookie settings in Chrome
  • Cookie settings in Safari web and iOS.

If you only want to limit third party advertising cookies, you can turn such cookies off by visiting the following links:

  • Your Online Choices (http://www.youronlinechoices.com/uk/)
  • Network Advertising Initiative (http://www.networkadvertising.org/)
  • Digital Advertising Alliance (http://www.aboutads.info/consumers)

Please bear in mind that there are many more companies listed on these sites than those that drop cookies via the Websites.

5. Changes to this Cookie Policy

We will occasionally update this Cookie Policy to reflect changes in our practices and services. When we post changes to this Cookie Policy, we will revise the "Last Updated" date at the top of this Cookie Policy. If we make any material changes in the way we collect, use, and/or share information held in cookies, we will notify you by prominently posting notice of the changes on the Websites. We recommend that you check this page from time to time to inform yourself of any changes in this Cookie Policy or any of our other policies.

6. Need More Information?

If you would like to find out more about cookies and their use on the Internet, you may find the following links useful:

  • All About Cookies
  • youronlinechoices.co.uk/uk

7. Cookies that have been set in the past

If you have disabled one or more Cookies, we may still use information collected from cookies prior to your disabled preference being set, however, we will stop using the disabled cookie to collect any further information.

8. Contact us

If you have any questions or comments about this cookies policy, or privacy matters generally, please contact us via email at [[email protected]] or the address provided below:

Harju maakond, Tallinn, Kesklinna linnaosa-Parda 4, 411-1, 10151.