This Privacy Policy governs how OTORIO Ltd. (“OTORIO” “we”, “our” or “us”) use, collect, and store Personal Data that we collect or receive from or about you, in the following use cases:
Please read this Privacy Policy carefully, so you can understand our practices and your rights in relation to Personal Data. “Personal Data” means any information that can be used, alone or together with other data, to uniquely identify any living human being and any information deemed as Personally Identifiable Information by applicable privacy laws. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant to GDPR-protected individuals. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.
Table of contents:
This Privacy Policy can be updated from time to time. Therefore, we ask you to check for the latest version of this Privacy Policy periodically. If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.
Specific personal data we collect |
Why is the personal data collected and for what purposes? |
Legal basis |
Third parties with whom we share your personal data |
Consequences of not providing the personal data |
When you make use of, or interact with, our Website |
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- Full name - Email address - Phone Number - Job title - Company Name - Company size - Industry - Country - State/Providence
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- To send you marketing communications - To send you OTORIO updates about our blog |
- Consent - Legitimate interest (e.g. send you more information about us in a B2B context) |
- Hubspot - Salesforce - Insycle - Klenty - AWS - Rollworks - Salesloft
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- Cannot send you marketing communications - Cannot send you updates about OTORIO´s blog |
When we process your job application |
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- Full name - Email address - Telephone number - CV – resume - Cover letter - Any other information that you decide to provide/supply us with |
- To assess you as a candidate - To communicate with you in connection with your job application |
Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g., to analyze your application) |
Comeet AWS |
- Cannot assess you as a candidate - Cannot communicate with you in connection with your job application |
When you contact us (e.g. support, help, chat, general inquiries, request a demo) |
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- Full Name - Email address - Phone Number - Job Position - Industry - Country - Any other information that you decide to provide/supply us with |
- To answer your query - To respond to your requests - To provide support and customer service - To customize your experience |
Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. provide support and answer your questions) |
Hubspot Salesforce Insycle Klenty AWS Rollworks Salesloft
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- Cannot answer your query - Cannot respond to your requests - Cannot provide support and customer service - Cannot customize your experience
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- Full name - Email address
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- To send you marketing communications |
Consent |
Hubspot Salesforce Insycle Klenty AWS Rollworks Salesloft |
- Cannot send marketing communication |
When you make use of, or interact with, our Platform | ||||
When you create an account and when you log in to our Platform |
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- Full name - Email address - User ID and Password |
- To create your account and allow you to create the admin and operator users - To allow you to log in to the Platform - To expose you only to the data you are allowed to see - To grant you access to the services (our Platform) |
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to allow you to sign up to the Platform) |
Azure |
- Cannot create your account - Cannot allow you to log in to the Platform - Cannot exclude you from seeing data that you are not allowed to see. - Cannot grant you access to the services (our Platform) |
When you attend a marketing event and/or we exchange business cards and you provide us with your Personal Data |
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- Full Name - Email Address - Company name - Job title - Phone number - Address - Company Name - Company size - Industry - Any other data you decide to provide/supply us with |
- To establish a first business connection/discussion - To send you marketing communications |
Consent Legitimate interest (e.g. to establish a business connection)
|
Hubspot Salesforce Insycle Klenty AWS Rollworks Salesloft |
- Cannot establish a first business connection/discussion - Cannot send you marketing communications |
When we acquire your Personal Data from third-party sources (such as lead-generation companies) |
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- Full Name - Job Title - Telephone Number - Address - Company Name - Industry - Any other data you decide to provide/supply us with |
- To establish a first business connection/discussion - To send you marketing communications |
Depending on the context, legitimate interest (B2B marketing), pre-contractual discussions or consent
|
Hubspot Salesforce Insycle Klenty AWS Rollworks Salesloft
|
- Cannot establish a first business connection/discussion - Cannot send you marketing communications |
When we use the personal data of our customers (e.g. contact details) |
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- Full name - Company name - Email address - Phone number - Any data available on LinkedIn profiles - Any other data you decide to provide/supply us with |
- To provide our products and services - To perform the applicable agreement - To communicate with our Customers/clients (e.g., to send you contract-related communications) - To provide to our wider sales team
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Processing is necessary for the performance of a contract to which our customer is a party.
Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.).
Legitimate interest (e.g. send you contract-related communications) |
Hubspot Salesforce Insycle Klenty AWS Salesloft |
- Cannot provide our products and services - Cannot perform the applicable agreement - Cannot communicate with our Customers/clients
|
- Full name - Email address |
- To send you marketing communications and other communications about our products and services |
Depending on the context, legitimate interest (B2B marketing or soft-opt in) or consent |
Hubspot Salesloft Insycle |
- Cannot establish a first business connection/discussion - Cannot send you marketing communications |
When we use the personal data of our service providers (e.g. contact details) |
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- Full name - Company name - Job title - Email address - Phone number - Any other data you decide to provide/supply us with |
- To contact our service providers/vendors - To perform the applicable agreement
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Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
Legitimate interest (e.g.to contact our service providers) |
AWS |
- Cannot contact our service providers/vendors - Cannot perform the applicable agreement
|
When you interact with us or provide us with your information via our social media profiles (e.g., Facebook, LinkedIn) |
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- Full name - Company name - Address - Email address - Phone number - Job Title - Any other data that you decide to supply/provide us and/or publicly available on your social media account |
- To reply and/or respond to your request or question - To provide you with content and information that you have requested. |
Consent Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. send you more information about OTORIO) Processing is necessary for compliance with a legal obligation to which the controller is subject |
Hubspot Salesforce Insycle Klenty Rollworks Salesloft |
- Cannot reply and/or respond to your request or question - Cannot provide you with content and information that you have requested. |
When you apply for a job with OTORIO as a candidate for a position at the company |
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- Full name - Address - Email address. - Curriculum Vitae (resume) - Information regarding your skills, work experience, education - Your LinkedIn URL and URLs for your other online profiles - The position for which you are applying - The source of who submitted your application (for example, recruitment agency or referral) - Email correspondence between you and OTORIO and OTORIO and other third parties (for example, recruitment agencies) about your candidacy and the application - Information from references - Information about events in the lifecycle of your candidacy - Your responses to any questionnaires sent to you by OTORIO - Information about your candidacy and employment options (such as availability to be hired and salary expectations) - Evaluations of your candidacy - Internal discussions within OTORIO about your candidacy - Materials you or other parties (such as evaluators or background check providers) submitted in relation to your candidacy - Any other data that you decide to supply/provide us and/or publicly available on your social media account |
- To to evaluate and consider you as a candidate for positions at OTORIO - To to contact you for your candidacy status and interviews - To schedule meetings and interviews with you - To communicate with you in order to provide you updates and other correspondence about your application. |
Consent Legitimate interest (e.g. send you more information about OTORIO) |
Comeet
Azure |
- Cannot evaluate and consider you as a candidate for positions at OTORIO. - Cannot contact you for your candidacy status and interviews with you. - Cannot schedule meetings and interviews. - Cannot communicate with you in order to provide you updates and other correspondence about your application.
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Please note that some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data will also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).
In addition to the recipients described above, we may share your Personal Data as follows: